Technological advancements over the last several years have made it easier than ever for employers and employees to collect, store, manage, organize, or transmit health information via applications and other software (collectively, “apps”). The Office of Civil Rights (“OCR”), the entity responsible for enforcing the Health Insurance Portability and Accountability Act (“HIPAA”), recently issued FAQs concerning HIPAA’s applicability to apps. The FAQs clarify that once protected health information (“PHI”) has been received by an app that is neither a covered entity nor a business associate, the information is no longer subject to the protections of the HIPAA rules.

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