Martin McKeay recently posted a blog entry on behalf of Eric Irvin that describes Google's personal health record services, and their posture relative to HIPAA requirements. The short version of the story is that Google apparently is not legally required to comply with HIPAA because they are neither a provider of healthcare services, nor a payer, hence they are not a covered entity as described in th
e HIPAA act language.

I agree with Eric that Google should comply with HIPAA privacy and security rule requirements, after all, they set a fairly low bar on the security side. I also think that CMS should start thinking about these cases, because we will see more of this in the near future, both from Google and Microsoft, but also from regional health information networks, and other medical record sharing entities that are not technically providers of healthcare services.

Jim