Elizabeth Brim

On March 24, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule establishing a Health Insurance Portability and Accountability Act (“HIPAA”) standard for electronic signatures in connection with health care claims attachments transactions, as well as standards governing the electronic exchange of claims attachments more generally. The rule adopts the first-ever standards for health care claims attachments under HIPAA.

At the state level, genetic privacy remains a fast-moving topic, and states continue to introduce and advance bills regulating genetic data. Several proposals that we covered in more detail earlier this year have progressed since our last update, including: Utah enacted HB 182, which regulates “foreign adversaries’” access to genetic sequencing information.

In late September, plaintiffs announced details regarding Google LLC’s (“Google”) and women’s health app developer, Flo Health Inc.’s (“Flo”) proposed settlements to resolve a class action lawsuit stemming from the Flo app’s allegedly unlawful sharing of health data with Google and others through online tracking technologies.