United States: HHS Office For Civil Rights Issues HIPAA Guidance On Workplace Wellness Programs
Shannon Hartsfield Salimone is a Partner in Holland & Knight’s Tallahassee office
In April 2015, the Department of Health and Human Services’ Office for Civil Rights (OCR) issued two “frequently asked questions” providing guidance on workplace wellness programs under the HIPAA Privacy, Security, and Breach Notification rules. OCR reiterated that employers, as such, are not covered entities. Therefore, whether HIPAA applies to an employer’s wellness program will depend on how the program is structured. The […]