HIPAA Reproductive Health Care Privacy Rule Vacated
This Bulletin is brought to you by AHLA’s Health Information and Technology Practice Group.
- July 22, 2025
- Jennifer Kreick , Haynes and Boone LLP
- Thomas Tanabe , Haynes and Boone LLP
On June 18, 2025, Judge Mathew J. Kacsmaryk of the U.S. District Court for the Northern District of Texas issued a Memorandum Opinion and Order in Purl v. United States Department of Health and Human Services vacating most of the 2024 amendments to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule (2024 Privacy Rule) for reproductive health care privacy. For covered entities and business associates (Regulated Entities), the nationwide vacatur provides some welcome clarity as to the future enforcement of the 2024 Privacy Rule, but Regulated Entities should continue to monitor the litigation landscape and review and potentially update their policies and forms (including removing previously-required attestations), training, and business associate agreements to align with the decision.
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