In this letter to the Treasury’s Federal Insurance Office, the Confidentiality Coalition supports extending federal catastrophe insurance backing to major cyber incidents. It also asks for continued public-private collaboration and outreach to improve cyber readiness.
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.
In this letter to House Energy and Commerce leaders, the Confidentiality Coalition thanks them for their work on the American Data Privacy and Protection Act. It urges HIPAA-aligned protections for health data outside HIPAA, including individual authorization and limits on use beyond the authorized purpose.
In this letter to HHS OCR, the Confidentiality Coalition responds to an RFI on implementing two HITECH Act provisions. It asks OCR to give regulated entities credit for the recognized security practices they have in place, using a sliding scale of reduced enforcement, and to limit payouts to harmed individuals to clear economic harm so OCR can prioritize its cybersecurity work.
The Confidentiality Coalition is responding to the FTC and DOJ’s Request for Information on Merger Enforcement, focusing specifically on competition issues in digital markets and the handling of health data during mergers.
The Confidentiality Coalition, chaired by the Healthcare Leadership Council, submitted comments to the Senate Commerce Committee emphasizing the urgent need to strengthen cybersecurity protections across the healthcare sector as attacks continue to rise sharply, exposing millions of patients and driving significant financial and operational harm. Citing a 55% increase in cyberattacks and a 72% surge in ransomware during the early months of COVID?19, the Coalition underscores that these threats jeopardize not only data security but patient safety. The letter supports increased federal investment in the Cybersecurity and Infrastructure Security Agency (CISA), applauds recent congressional action allowing HHS to consider recognized cybersecurity practices when assessing HIPAA breach penalties, and encourages continued federal focus on education, prevention, and collaboration. The Coalition reaffirms its commitment to working with policymakers to advance strong, practical, and patient?centered cybersecurity strategies across healthcare.
In this letter to the Senate Commerce Committee leaders, the Confidentiality Coalition urges HIPAA-aligned privacy protections for health data collected outside HIPAA, such as by consumer apps. It encourages the FTC to develop privacy standards and Congress to pass national privacy legislation.
In this letter to House Energy and Commerce leaders, the Confidentiality Coalition urges HIPAA-aligned privacy protections for health data collected outside HIPAA, partially due to the surge in data collected during COVID-19. It encourages the FTC to examine health data protections and Congress to pass national privacy legislation, with patient consent required for sharing and limits on use beyond the consented purpose.
In this letter to NCVHS, the Confidentiality Coalition says COVID-19 showed that health data is hard to share because there’s no single data standard and reporting metrics differ across federal, state, and local levels. It asks HHS to create common standards, and to make sure privacy protections are in place before data outside HIPAA is shared.
In this letter to HHS OCR, the Confidentiality Coalition supports HHS’s proposed HIPAA changes to make care coordination easier, but warns that patients lose privacy protection when their records go to third-party apps outside HIPAA. It asks for stronger rules for those apps, more consistent interoperability rules, and an end to the accounting of disclosures rulemaking.
