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Network for Public Health Law Comments on Proposed HIPAA Privacy Rule to Bolster Privacy of Reproductive Health Information

The U.S. Department of Health and Human Services’ Office for Civil Rights (OCR/HHS) recently announced proposed changes to the HIPAA Privacy Rule to bolster the privacy of protected health information related to reproductive health care. The Network for Public Health Law (Network) supports the proposed changes and has submitted comments to this effect. The critical importance of HHS’ proposed rulemaking is highlighted by the sheer reality of reproductive health in the U.S. post-Dobbs. Reproductive health-related civil and criminal consequences pose a barrier to achieving health equity and health justice. Protecting the privacy of reproductive health information is paramount to preventing inequitable enforcement of state laws criminalizing health care access.

The Network’s comments address several specific and general questions posed by OCR/HHS in the Request for Comments. Read the Network’s full comments.

For a summary of the proposed changes, read our recent article.

If you are a health agency or care service provider with questions about the HIPAA Privacy Rule and reproductive health care, the Network can help – connect with us here.

The notice of proposed changes to the Privacy Rule was published in the Federal Register on April 17, 2023, and comments must be submitted by June 16, 2023. Anyone can submit comments on the proposed changes and comments may be submitted electronically at by searching for the Docket ID number HHS–OCR–0945–AA20.


The Network advances the use of law and policy to improve lives and make communities safer, healthier, stronger, and more equitable. Through the provision of non-partisan legal technical assistance, resources, and training, the Network collaborates with a broad set of partners across sectors to expand and enhance the use of practical legal and policy solutions.