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Tracking Health Information Using Online Technologies: New OCR Guidance, HIPAA Obligations for Regulated Entities


Mar. 1, 2023
Recorded Online

This CLE webinar will guide healthcare counsel on the use of tracking technologies by covered entities (CE) and business associates (BA). The panel will discuss the new U.S. Dept. of Health and Human Services Office for Civil Rights (OCR) guidance and the impact on how CEs and BAs use tracking technologies. The panel will offer best practices for healthcare entities in light of the guidance and to ensure HIPAA compliance.


OCR issued guidance on the use of tracking technologies by CEs and BAs. The guidance highlights the HIPAA privacy and security obligations when CEs and BAs use online tracking technologies. An IP address is both an identifier and an individually identifiable health information when collected on a healthcare entity's website.

HIPAA applies when tracking technologies collect the email or IP address when the individual visits a CE's webpage to schedule appointments with his/her provider. OCR notes that this may apply when the website addresses specific symptoms or health conditions.

CEs should review and evaluate their relationships with tracking technology vendors to determine whether any data disclosed is protected health information (PHI) and whether the vendor is a BA. CEs also need to ensure HIPAA compliance regarding its disclosures with the vendors.

Listen as our authoritative panel of healthcare attorneys examines how the guidance impacts how CEs and BAs use tracking technologies and evaluate such usage considering the significant regulatory and litigation activity against CEs and BAs regarding their use of this technology. The panel will also offer best practices for healthcare entities in light of the guidance and to ensure HIPAA compliance.

More Information, How to Register

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