CHA News

CHA Comments on Proposed Regulations on Privacy Breach Reporting

For privacy officers, legal counsel, licensing & certification staff

This post has been archived and contains information that may be out of date.

CHA has submitted comments  to the California Department of Public Health on its proposed regulations on privacy breach reporting. In its letter, CHA makes recommendations in several key areas.  

Those areas include:

  • Revising the regulations to recognize that the authorizing statute imposes a negligence standard, not a strict liability standard 
  • Clarifying that hospitals are not responsible for breaches by business associates, medical staff members, or their employees 
  • Making definitions consistent with existing statutory and case law 

Questions on CHA’s comments can be directed to Lois Richardson, vice president & legal counsel, at