HIPAA Final Rule on Reproductive Health Care Privacy Struck Down

In June 2024, the U.S. Department of Health & Human Services’ Office for Civil Rights (HHS) issued a Final Rule modifying the HIPAA Privacy Rule to enhance reproductive health care privacy affecting all HIPAA covered entities and their business associates. Most compliance obligations, which include revisions to policies and procedures, updates to personnel training and other implementations, began December 23, 2024.

On June 18, 2025, U.S. District Judge Matthew Kacsmaryk in the Northern District of Texas found that, “HHS lacked clear delegated authority to fashion special protections for medical information produced by politically favored medical procedures” in connection with a suit brought by a Texas doctor, Purl v. Dep’t of Health and Human Services, N.D. Tex., No. 2:24-cv-00228. Judge Kacsmaryk’s decision vacated the Final Rules modifications of HIPAA regulations at 45 C.F.R. parts 160 and 164.