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 email@example.com.