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Quick Answer

What Is HITECH Act?

HITECH is the 2009 federal law that strengthened HIPAA by extending direct liability to business associates, increasing breach notification requirements, and creating tiered civil monetary penalties for HIPAA violations.

  • Billing companies onboarded after 2013 (when the HITECH Omnibus Final Rule took effect) are directly liable for Security Rule violations regardless of what the BAA says.
  • Practices should verify that their billing partner conducts annual risk analyses and maintains breach notification procedures meeting 45 CFR 164.404.
Compliance

HITECH Act

Also known as: Health Information Technology for Economic and Clinical Health Act; HITECH

HITECH is the 2009 federal law that strengthened HIPAA by extending direct liability to business associates, increasing breach notification requirements, and creating tiered civil monetary penalties for HIPAA violations.

Definition

The Health Information Technology for Economic and Clinical Health Act was enacted as Title XIII of the American Recovery and Reinvestment Act of 2009. HITECH made business associates directly liable for HIPAA Security Rule compliance and for impermissible uses and disclosures under the Privacy Rule. It introduced the Breach Notification Rule (now codified at 45 CFR 164.400-414) requiring notification to affected individuals, HHS, and in some cases media. It also established the four-tier civil penalty structure (from 'did not know' to 'willful neglect, not corrected') and created the Meaningful Use program that drove EHR adoption.

Example

Under HITECH, a clearinghouse that suffers a ransomware attack exposing 600 patient records must notify each affected individual within 60 days, notify HHS via the OCR breach portal, and notify prominent media outlets in the affected state because the breach exceeds 500 individuals.

Common Misconceptions

HITECH did not replace HIPAA — it amended and strengthened it. Many practices believe HITECH only applies to EHR vendors due to the Meaningful Use connection, but the breach notification and direct business associate liability provisions apply to every billing company, clearinghouse, and IT vendor that handles PHI.

Practical Application

Billing companies onboarded after 2013 (when the HITECH Omnibus Final Rule took effect) are directly liable for Security Rule violations regardless of what the BAA says. Practices should verify that their billing partner conducts annual risk analyses and maintains breach notification procedures meeting 45 CFR 164.404.

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