On November 26, 2012, the Department of Health and Human Services Office for Civil Rights (“OCR”) published a thirty-two page document titled “Guidance Regarding Methods for De-identification of Protected Health Information in Accordance with Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule” (“De-Identification Guidance”).  OCR described the guidance document as a culmination of two years of work by “stakeholders with practical, technical and policy experience in de-identification.”  OCR also acknowledged that the guidance implements many of the issues and topics that were raised during an OCR workshop held in Washington, DC on March 8-9, 2010.