On June 2, 2026, Connecticut Governor Ned Lamont signed Senate Bill 5 into law, designated as Public Act 26-15 and also known as the Connecticut Artificial Intelligence Responsibility and Transparency Act (the “CART Act” or “Act”).1 The CART Act is among the most comprehensive state AI laws enacted to date, creating distinct obligations for employment-related automated decision tools, consumer chatbots, frontier-model developers, generative-AI provenance, and online platforms used by minors, while also addressing AI applications in healthcare through targeted carveouts and innovation initiatives.
Continue Reading Connecticut Enacts Sweeping AI Law Covering Employment, Healthcare, and Online Safety
HHS OCR Announces Civil Enforcement Program for Confidentiality of Substance Use Disorder Patient Records
On February 13, 2026, the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) announced its civil enforcement program to implement the updates to the Substance Use Disorder (“SUD”) confidentiality provisions of the regulation at 42 CFR Part 2 (“Part 2”).1 The new enforcement program became effective February 16, 2026, in accordance with the deadline set by the 2024 Final Rule modifying Part 2 (“2024 Final Rule”).
Continue Reading HHS OCR Announces Civil Enforcement Program for Confidentiality of Substance Use Disorder Patient RecordsChange Healthcare Cyberattack: HHS OCR Publishes Early Guidance on Breach and UnitedHealth Group Provides Critical Status Update
On March 13, 2024, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced that it had opened an investigation into the monumental cyberattack on Change Healthcare (“Change”), a unit of UnitedHealth Group (“UHG”). The attack is one of the largest assaults against the U.S. health care system, with far-reaching
Health and Human Services Proposes Changes to Part 2 Regulations Concerning Substance Use Disorder Records to Further Align with HIPAA
For decades, health care providers that are subject to both HIPAA and to the specialized Confidentiality of Substance Use Disorder (“SUD”) Patient Records regulations (known as “Part 2”) have had to navigate differing, and at times divergent, privacy and confidentiality rules applicable to patient health information and patient records. These disparate privacy rules have, for many
FTC Warns Health Apps and Connected Device Companies to Comply With Health Breach Notification Rule
Modern smartphones, wearables and internet-enabled devices are capable of monitoring heart rate, blood oxygen levels, steps taken, prescription adherence, and other vital health-related activities. Contrary to popular belief, HIPAA does not cover many of these applications and devices. On September 15, 2021, the Federal Trade Commission issued a Policy Statement attempting to assert authority to police that gap. The Policy Statement explains the FTC’s view that the Health Breach Notification Rule applies to mobile health applications. This Policy Statement signals increasing FTC scrutiny designed to safeguard sensitive health data on a variety of modern technologies that consumers use to monitor and improve their health.
Continue Reading FTC Warns Health Apps and Connected Device Companies to Comply With Health Breach Notification Rule