UPDATE (April 17, 2025): The below reflects a development occurring after our publication of the original post.

On April 11, 2025, the National Security Division (the “NSD”) released several documents setting out initial guidance on how to comply with the Rule, which the NSD refers to as the Data Security

On July 20, 2023, the Federal Trade Commission (“FTC”) and the Office for Civil Rights of the United States Department of Health and Human Services (“OCR”) announced that they had sent a warning letter to about 130 hospital systems and telehealth providers, alerting them about the risks and concerns of using online tracking technologies, such as the Meta/Facebook pixel and Google Analytics, which can track users’ online activities.