The American Health Information Management Association supports many of the provisions in the HHS Office for Civil Rights' proposed rule governing accounting of disclosures under the HIPAA privacy rule and applauds OCR for "an excellent job updating this rule." But the association has serious concerns about provisions that give patients the right to an access report about who has accessed their electronic health records.

AHIMA does not believe there has been enough time for the industry to work with OCR to development a set of access requirements that satisfy the needs of individuals or acquire the resources needed to collect and create the reports, according to a comment letter to OCR Director Georgina Verdugo.

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