Jennifer S. Geetter

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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.

FTC Amends Health Breach Notification Rule to Regulate Health Apps and Expand Breach Notification Requirements

By , , , and on Jun 26, 2024
Posted In Digital Health, Privacy and Data Security

On April 26, 2024, the Federal Trade Commission (FTC) issued a final rule to amend its Health Breach Notification Rule (HBN Rule). The HBN Rule works as a compliment and counterpart to the breach notification requirements established under the Health Insurance Portability and Accountability Act (HIPAA) for HIPAA-regulated entities. Specifically, the HBN Rule requires that...

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OCR Update on Tracking Technologies Provides Little Relief for HIPAA-Regulated Entities

By , , , , and on May 14, 2024
Posted In Digital Health, Employee Benefits, Health and Welfare Plans, Privacy and Data Security

On March 18, 2024, the US Department of Health and Human Services Office for Civil Rights (OCR) issued an update to its December 1, 2022, bulletin titled “Use of Online Tracking Technologies by HIPAA Covered Entities and Business Associates.” In releasing the 2024 update, OCR stated that its purpose was to “increase clarity for regulated...

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Healthcare Payors and Providers and AI Companies Voluntarily Commit to AI Principles

By , and on Jan 17, 2024
Posted In Digital Health, Employee Benefits, Health and Welfare Plans, Privacy and Data Security

The Biden administration recently announced that 28 healthcare payors and providers intend to implement and adhere to voluntary commitments for the safe, secure and trustworthy development and deployment of artificial intelligence (AI) in healthcare. The signatory companies aligned around the FAVES principle—namely, that AI should lead to healthcare outcomes that are fair, appropriate, valid, effective...

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FTC Proposes Health Breach Notification Rule Amendments

By , and on Jun 20, 2023
Posted In Digital Health, Employee Benefits, Health and Welfare Plans

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...

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HHS Issues Guidance on Requirements Under HIPAA for Online Tracking Technologies, Addressing Privacy and Security Concerns Related to Health Information

By , , , , and on Dec 20, 2022
Posted In Privacy and Data Security

On December 1, 2022, the Office for Civil Rights (OCR) at the US Department of Health and Human Services (HHS) issued a Bulletin on the obligations of covered entities and business associates (regulated entities) under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy, Security, and Breach Notification Rules (HIPAA Rules) when using online tracking...

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The “New” Digital Healthcare Delivery System

By and on Nov 18, 2021
Posted In Digital Health, Employee Benefits, Health and Welfare Plans

Although digital health solutions have long been a key area of strategic growth for the healthcare industry, the COVID-19 crisis accelerated what it means to deliver safe and effective digitally-based care. As the United States shifts focus from short-term crisis response to longer-term solutions, what does a digitally-driven healthcare industry look like, and how can...

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All Hands on Deck: How Employers Can Expedite Vaccine Roll-Out for Employees and Their Loved Ones Using the Closed Point of Dispensing (CPOD) Model

By on May 25, 2021
Posted In Health and Welfare Plans

McDermott Will & Emery lawyers Jennifer S. Geetter and Allyn N. Rosenberger recommend that employers consider using a “closed point of dispensing” model to expedite COVID-19 vaccinations for their workforce by arranging for health care providers to inoculate employees using government-provided vaccines. Access the article.

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Transformative Healthcare Collaboration Opportunities Emerge from COVID-19 Pandemic

By , , , , , , and on Feb 17, 2021
Posted In Employee Benefits, Health and Welfare Plans, Privacy and Data Security

The seismic, virtually overnight transformation of healthcare delivery as a result of the pandemic has flung open doors to innovation, as a diverse cross-section of digital health and life sciences stakeholders mobilize crisis resources; adjust operations for enhanced screening, sanitization and social distancing measures; harness telehealth capabilities to deliver healthcare remotely; and identify opportunities for...

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Digital Health as Healthcare Delivery: A Path to Transform Care Delivery Post-Pandemic

By on Dec 31, 2020
Posted In Employee Benefits, Health and Welfare Plans, Privacy and Data Security

As has been widely noted, the COVID-19 pandemic has prompted countless people to rely on telehealth and virtual monitoring for their healthcare needs. This dramatic pivot is catalyzing a demand for digital health tools that will persist post-pandemic, as providers, payers and patients alike grow accustomed to the benefits of digital care. In a recent...

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The Toughest Problem Set: Navigating Regulatory and Operational Challenges on University Campuses

By , and on Sep 24, 2020
Posted In Employment, Labor, Privacy and Data Security

Because widespread, rapid COVID-19 testing remains unavailable in many locations, universities have had to find innovative ways to implement testing, tracing and isolation protocols to reduce the risk of transmission among students, faculty and staff. There is no one perfect protocol—all universities are in unchartered waters. But there are a few key components university administrators...

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