On June 18, 2025, the U.S. District Court for the Northern District of Texas vacated most of the HIPAA Reproductive Health Care Privacy Rule. This rule was introduced on April 26, 2024, under the Biden Administration and became applicable on December 23, 2024. The rule aimed to enhance privacy protections related to protected health information (PHI) in reproductive health care.
The 2024 rule added definitions and restricted HIPAA-covered entities and business associates from disclosing reproductive health information for purposes like criminal or civil investigations or imposing liability on individuals seeking or providing reproductive health care.
However, a recent decision in Texas (Purl v. U.S. Department of Health and Human Services) left a small portion of the amendment intact. The requirement for covered entities to update their HIPAA Notice of Privacy Practices (NPPs) regarding PHI use in reproductive health care and confidentiality of substance use disorder records remains effective until February 16, 2026.
HIPAA-regulated entities previously had to comply with the Biden Administration's rule by adjusting policies and training materials. These changes may now revert to pre-2024 guidance. Employers are advised to delay further edits until HHS releases its model notice.
There is no expectation that the Trump Administration will appeal the Purl decision, nor is further enforcement from HHS anticipated regarding the 2024 rule. HHS stated that next steps will be evaluated after reviewing the court's decision.
We will continue monitoring developments and provide updates if necessary.