Time is up, and the enforcement infrastructure is now live. OCR’s complaint portal is open to 42 CFR Part 2, and Part 2 breach reporting is no longer a future workflow. A live portal changes behavior: it lowers the friction
Oscislawski LLC Blogs
Latest from Oscislawski LLC
ONC Quietly Dropped Four (4) New Information Blocking FAQs
Are You Blocking? The Coming Crackdown on Information Blocking: What It Means for HIE/HINs, Developers of Certified HIT, & Health Care Providers
When HHS Secretary Robert F. Kennedy, Jr. announced on September 3, 2025, that the Department would launch an aggressive crackdown on information blocking, it signaled a turning point in federal health IT policy. For years, patients, innovators, and providers
Bookmark This! Copies of All 42 CFR Part 2 Rules Published from 1974 to 2024
If you’ve ever wasted precious time chasing down what feels like endless versions of 42 CFR Part 2, I feel your pain. To save myself (and you) from that frustration, I pulled together every single Notice of Proposed Rulemaking (NPRM)
Beware! New Breach Reporting Obligations Under 42 CFR Part 2 — Even When HIPAA Wouldn’t Require It
Starting February 16, 2026, Part 2 programs and providers will be required to report unauthorized disclosures of Part 2 information – specifically, any “acquisition, access, use, or disclosure” that violates 42 CFR Part 2. This is a major change that
From Dragging Feet to Dragged Along: The Uneven March Into TEFCA
On August 6, 2025, the Assistant Secretary for Technology Policy (ASTP) at ONC publicly announced its release of the TEFCA Organizational Map, a beta search tool that allows users to look up which organizations are participating in the Trusted
Audacious Inquiry Sues CRISP: A Patent Showdown with National Interoperability Implications
A new lawsuit filed yesterday in the U.S. District Court for the District of Maryland has the potential to reshape the contours of health information exchange in the United States. Audacious Inquiry, LLC, a Baltimore-based health IT innovator now owned
Regulatory Roller Coaster: District Court Judge Vacates HIPAA Reproductive Health Privacy Rule
Who feels like they’ve been on a regulatory roller coaster lately?On June 18, 2025, in Purl v. U.S. Department of Health & Human Services, Judge Kacsmaryk of the U.S. District Court for the Northern District of Texas vacated key provisions of HHS’s HIPAA
Does the TEFCA Exception Hinder Participation?
On May 16, 2025, HHS published a Request for Information (RFI), 90 Fed Reg 21034, inviting public comment on the future of the TEFCA exception within the federal information blocking rules. Issued jointly by the CMS and the Assistant