tag:blogger.com,1999:blog-4384692836709903146.post7749174411278723106..comments2024-03-18T04:38:01.678-07:00Comments on Dispatch from the Digital Health Frontier: The Timeline for ARRA Privacy ProvisionsJohn Halamkahttp://www.blogger.com/profile/04550236129132159307noreply@blogger.comBlogger7125tag:blogger.com,1999:blog-4384692836709903146.post-30846147305134455142009-06-16T12:57:26.598-07:002009-06-16T12:57:26.598-07:00I agree with Jana that something should be added r...I agree with Jana that something should be added regarding the effective date of the breach notification provisions, but it may not be 9/16/09 if the interim final regulations are promulgated before the 180-day deadline to do so. Perhaps it could be something like "Sept. 16, 2009, or 30 days after the interim final regulations are promulgated, whichever comes earlier." Thank you for your work on the timeline.<br /><br /><br />Recep Deniz MD<br /><br /><a href="http://www.doktortr.net/" title="DoktorTR.Net - Tıp Sitesi" rel="nofollow">DoktorTR.Net</a>Football Matcheshttps://www.blogger.com/profile/00341831327324203736noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-19865207739120162192009-05-05T02:30:00.000-07:002009-05-05T02:30:00.000-07:00Its really very interesting blog..i will always gr...Its really very interesting blog..i will always grateful to you for information posted in this blog.<br />Learn here about <A HREF="http://www.obituarieshelp.org/sympathy_sayings.html" REL="nofollow">sympathy words</A>Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-23344130190033688602009-03-30T05:42:00.000-07:002009-03-30T05:42:00.000-07:00I realize this isn't quite on topic but in reading...I realize this isn't quite on topic but in reading the various provisions of section 13400 I am bothered by having yet another definition of what a data breach is. Almost every state has spelled out (differing) defintions of what a data breach is, while the feds have virtually no codified definition ourside of OMB M-07-16. It seems while it may not be possible to avoid such distinctions, any effort to minimize multiple definitions of what a data breach is would go a long way to keeping things understandable and manageable for citizens and businesses.<BR/><BR/>I don't mean to try and bolix things up, but I can see a lot of confusion over classifying (in order to respond) a data exposure incident involving a mix of medical and non-medical PII. <BR/><BR/>It seems smart folks are working on this, I just hope they don't build a medical information data breach "silo" that now competes with other data breach laws and regs rather than complement.Johnhttps://www.blogger.com/profile/13052019507031996684noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-69306597343474736772009-03-26T13:53:00.000-07:002009-03-26T13:53:00.000-07:00I agree with Jana that something should be added r...I agree with Jana that something should be added regarding the effective date of the breach notification provisions, but it may not be 9/16/09 if the interim final regulations are promulgated before the 180-day deadline to do so. Perhaps it could be something like "Sept. 16, 2009, or 30 days after the interim final regulations are promulgated, whichever comes earlier." Thank you for your work on the timeline.Unknownhttps://www.blogger.com/profile/09583089849383522094noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-54386361883454769532009-03-17T20:42:00.000-07:002009-03-17T20:42:00.000-07:00Thanks Jana - very helpful!Thanks Jana - very helpful!John Halamkahttps://www.blogger.com/profile/04550236129132159307noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-14080348818853084232009-03-17T19:31:00.000-07:002009-03-17T19:31:00.000-07:00You need to add September 16, 2009 as the date on ...You need to add September 16, 2009 as the date on which the breach notification provision becomes effective. (Section 13402) This is 30 days after DHHS and the FTC issue interim final regulations about breach notification.Jana Aagaardhttps://www.blogger.com/profile/11601548672832181514noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-85247658958516167652009-03-17T11:41:00.000-07:002009-03-17T11:41:00.000-07:00Check out the HHS Recovery Webcasthttp://www.hhs.g...Check out the HHS Recovery Webcast<BR/><BR/>http://www.hhs.gov/recovery/webcast_captioned.htmlAhierhttps://www.blogger.com/profile/13398190978662246852noreply@blogger.com