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The Healthcare Leadership Council (HLC) and the Confidentiality Coalition support strengthening cybersecurity for electronic protected health information (ePHI) but argue that the proposed HIPAA Security Rule changes are overly prescriptive, unrealistic, and burdensome. They urge the Office for Civil Rights (OCR) to maintain a risk-based approach and significantly revise several provisions.

In this letter to the FCC, the Confidentiality Coalition asks the agency to coordinate its data breach reporting rules with HHS, CISA, the FTC, and state laws so an incident only has to be reported to one federal agency. It points out that healthcare already faces heavy breach reporting requirements and is a frequent target of ransomware.

In this letter to the FTC, the Confidentiality Coalition responds to the commercial surveillance rulemaking by arguing that HIPAA should stay in place for health data it covers. It asks for HIPAA-aligned national protections for health data held by non-HIPAA entities, including clear notice, consumer authorization, and risk-based security standards with a safe harbor for recognized security practices.