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HHS Publishes Final Changes to HIPAA Privacy Rule

Client Alert | 1 min read | 08.15.02

On Wednesday, August 14, 2002, the Secretary of the Department of Health and Human Services ("HHS") published in the Federal Register revised Standards for Privacy of Individually Identifiable Health Information ("Final Rule") under the Health Insurance Portability and Accountability Act of 1996, P.L. 104-191 ("HIPAA"). Most health care entities must be fully compliant with the Final Rule by April 14, 2003. The changes set forth in the Final Rule modify privacy standards originally promulgated in December 2000 ("Privacy Rule"), and are substantially similar to changes to the Privacy Rule proposed by HHS in a March 2002 Notice of Proposed Rulemaking ("March NPRM"). The Final Rule - available at www.hhs.gov/ocr/hipaa - is intended "to maintain strong protections for the privacy of individually identifiable health information while clarifying certain of the Privacy Rule's provisions, addressing the unintended negative effects of the Privacy Rule on health care quality or access to health care, and relieving unintended administrative burdens created by the Privacy Rule." more...

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Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...