Discover and read the best of Twitter Threads about #curesact

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1/

An interesting wrinkle of #CuresAct

Adhering to contractual requirements is *not* one of the 7 exceptions to information blocking.

Tagging the smartest health policy lawyers I know:

@HealthPrivacy @JodiDaniel @SavageLucia

(Joy Pritts has no Twitter handle?)
2/

Historically, when BAA terms or other contractual terms conflicted with rights possible under #HIPAA, BAA terms have been deemed to hold.

E.g., famously, even though a clearinghouse is a HIPAA CE & has all the rights and obligations of a CE...
3/

...Clearinghouses *also* act as BAs and receive data under a BAA.

Other #HealthIT entities are pure BAs but are also deemed #HealthIT by Cures and this NPRM
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