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August 1, 2023

Generally, AMIA encourages FTC to ensure that HBNR and HIPAA are aligned such that there are no gaps in regulation over the covered entities and other non-covered entities that work with PHR; to align definitions with other agencies, including the definition of PHR; and to provide clarity around whether a non-health data source is being used in a health context and qualifies for coverage under the HBNR. AMIA also strongly encourages interagency coordination on such issues, particularly regarding standardizing definitions of terms and processes of addressing breaches.