HHS Releases Supplemental HIPAA Regulations
Client Alert | 1 min read | 06.01.02
On Friday, May 31, 2002, HHS released three new rules affecting electronic transactions and code sets under HIPAA. First, HHS issued a Final Rule which adopts as the "standard unique employer identifier" for HIPAA transactions, the employer identification number assigned by the IRS. This final rule is substantially the same as initially proposed. The second is a proposed rule which would modify standards for certain retail pharmacy transactions (specifically, referral certification and authorization, health care payment and remittance advice, and certain batch transactions) and would repeal the adoption of National Drug Codes (NDC) as the standard medical data code set for reporting drugs and biologics for all standard transactions (excluding retail pharmacy transactions), thereby allowing the industry to utilize nonstandard coding systems. HHS requests comment on the adoption of HCPCS as an alternative standard code set for reporting drugs and biologics for non- retail pharmacy transactions. Third, HHS issued a proposed rule which would adopt, by reference, certain limited technical modifications to some of the transactions standards previously identified by the Designated Standard Maintenance Organizations and approved by National Committee on Vital and Health Statistics. The proposed rule does not list these modifications specifically, but rather, refers to the hipaa-dsmo.org website.
Insights
Client Alert | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26
