The Pulse

Puzzling Proposed Pivot

By Matt Fisher – The Centers for Medicare and Medicaid Services released its proposed 2027 Physician Fee Schedule for Medicare (the 27 PFS) on July 14, 2026. The 27 PFS contained a pretty big surprise: a complete shift in approach to the two primary modes of remote monitoring: remote physiologic monitoring and remote therapeutic monitoring.

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Waiting and Waiting for Security Updates

By Matt Fisher – The biggest recent news for HIPAA is the quiet reveal that updates to the Security Rule are now delayed until sometime in the middle of 2027. The update was made on an Office of Management and Budget webpage, which now shows expected final action as an undefined date in July 2027.


Painful, But Notice Mandatory

By Matt Fisher – Revealing a data breach can be a hard action for an organization to take. The ongoing stream of notifications still generates attention, which is typically not positive when a security breakdown is revealed. At the same time, the notification is (or should be) unavoidable since the HIPAA breach notification rule is clear about what action is necessary.


Free the Data

By Matt Fisher – Access to data and the enablement of data flow are significant issues and concerns within healthcare. In particular, individuals often have a hard time getting to their own data. Those difficulties exist even with different regulations in place designed to promote and require access to data.


Do Your Risk Analysis

By Matt Fisher – The drumbeat of settlement agreements for alleged HIPAA violations by the Office for Civil Rights is continuing along with the consistent finding that the required risk analysis did not occur. The consistent announcement of settlements offers regular reminders to the healthcare industry that OCR is watching and expecting compliance to improve.


Be Truthful to Get Patients

By Matt Fisher – Imagine this scenario: an individual is suffering from substance use disorder and decides to seek help. A big reason for not getting treatment is reportedly not knowing how or where to get treatment, not being able to afford the treatment, and/or not finding a program or clinician where they wanted to be able to go.


Insider Risks

By Matt Fisher – The risk to privacy and security of healthcare information, despite all of the headlines, does not only come from outside attackers. Inside threats are real and can go undetected for potentially longer periods of time.


Breach Report Begets Settlement

By Matt Fisher – Whenever an entity subject to HIPAA experiences a data breach, notification must be given to the Office for Civil Rights. Once OCR receives notification of a breach, an investigation will typically follow. That combination is a sure way for broader issues to be uncovered. That is the scenario that played out in the most recent settlement announced by OCR.


Always Listening, Always Leaking?

By Matt Fisher – Ambient listening technology is growing in many areas and being incorporated into a lot of different applications. What does the ambient listening do? It automatically picks up conversations and other sounds around it to be processed for one purpose or another.