FTC Proposes Health Breach Notification Rule Amendments

At a recent open Commission meeting, the Federal Trade Commission (FTC) voted unanimously to issue a Notice of Proposed Rulemaking to amend the Health Breach Notification Rule (HBNR). The FTC’s proposed amendment aims to codify the HBNR’s application to digital health and mobile technologies. However, several aspects of the proposed amendment lack clarity and are likely to cause confusion unless further clarified through the ongoing rulemaking process.

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Jennifer S. Geetter
Jennifer S. Geetter advises global life sciences, health care and informatics clients on legal issues attendant to biomedical innovation, research compliance, financial relationship management, digital health practices, and global privacy and data security laws. Jennifer represents a broad range of clients. Read Jennifer Geetter's full bio.


Edward G. Zacharias
Edward G. Zacharias is the managing partner of McDermott’s Boston office. Clients across the healthcare industry and beyond turn to him for practical, business-oriented counsel on their most significant privacy and cybersecurity compliance, healthcare regulatory and transactional matters. Ed’s clients include “Big Tech” companies, health information technology and digital health companies, healthcare providers, insurers, electronic health record platforms, pharmacies, drug and device manufacturers, life sciences companies and health services vendors. Read Edward Zacharias' full bio.


Purnima Boominathan
Purnima Boominathan delivers full-spectrum legal counsel to venture-backed and public companies providing business-to-business services in the digital health space. She has particular expertise facilitating the creation, delivery and implementation of telemedicine. Purnima advises innovators working at the intersection of artificial intelligence and healthcare and offers practical insights into healthcare data privacy and legal issues related to at-home laboratory services. Read Purnima Boominathan's full bio.

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