Employer Action Items:
- December 23, 2024: By December 23, 2024, HIPAA-covered entities and business associates must be prepared to comply with the new restrictions by doing the following:
- Update HIPAA Policies and Procedures and Business Associate Agreements to address the new requirements.
- Review and amend Business Associate Agreements to ensure liability and indemnification is properly addressed, if necessary.
- Implement attestation process. HHS has provided a Model Attestation for covered entities and business associates to use.
- Inform employees and provide training on revised HIPAA Policies and Procedures.
Model Attestation
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