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On Jan. 25, 2013, the Department of Health and Human Services (HHS) published the “Final Rule” modifying the regulations under the Health Insurance Portability and Accountability Act (HIPAA). The Final Rule, which took effect on March 26, 2013, modified the standards previously set forth in the Privacy Rule, the Security Rule and the Enforcement Standards, and implemented statutory amendments under the Health Information Technology for Economic and Clinical Health (HITECH) Act by modifying the interim Breach Notification Rule. This article examines the Final Rule’s impact on business associates, such as certain third party administrators, consultants and accountants, and offers practical steps for compliance with the Final Rule by the Sept. 23, 2013, deadline.

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