Did the final modifications to the HIPAA Privacy Rule alter the compliance date(s) for covered entities?
No. The compliance dates for the Privacy Rule, as modified, remained April 14, 2003, for most health plans, covered health care providers, and health care clearinghouses, and April 14, 2004, for small health plans. Under HIPAA, compliance with a modification to an existing standard or implementation specification is required by a date set by the Secretary, but not earlier than 180 days from the adoption of the modification. By publishing the modifications to the Privacy Rule in August 2002, the original compliance date of April 2003 was maintained for the entire Rule, as modified.