Publications

On the Friday before a long Memorial Day weekend, the Office for Civil Rights (“OCR”) in the U.S. Department of Health and Human Services released proposed changes to its regulations implementing the Patient Protection and Affordable Care Act’s nondiscrimination regulations. The proposed changes are largely consistent with the Trump administration’s […]

In March 2019, the European Parliament voted to adopt new legislation regarding online content, and, in April, the European Union (the “EU”) member nations approved the Parliament’s directive. The Directive on Copyright in the Digital Single Market (the “Directive”) is intended to harmonize EU law with international law and to […]

Last month, we updated you on the proposed Washington Privacy Act (SB 5376) and the fact that the law, if passed, would mirror the European Union’s General Data Protection Regulation (“GDPR”). Despite passing the Washington Senate almost unanimously and being supported by the technology industry, the bill hit a roadblock […]

This May, Timothy Noonan (“Noonan”), acting deputy director for health information privacy at the Office for Civil Rights (“OCR”), sat for a Q&A session at the International Association of Privacy Professional’s (“IAPP”) annual Global Privacy Summit in Washington, DC. Noonan discussed a variety of topics, including OCR’s HIPAA enforcement priorities, […]

In a May 1, 2019, Revenue Procedure, the IRS expanded the determination letter program to reach statutory hybrid plans and plan mergers. As background, in 2017, the IRS significantly narrowed the application of its determination letter program for individually designed qualified plans. Prior to 2017, individually designed retirement plans were […]