Health Breach Notification Rulemaking
See attached document for comments. My primary concern is that the rules make sense, that they be easy to understand as both a covered entity and as a consumer and that the federal government take active steps to harmonize rules that cover electronic medical information and avoid building silos. If the data is important, then the rule and consequences that cover the infomration should not differ based on whether the entity is covered under FTC or HIPAA rules, or other rules. From a citizen centric view, the rules and consequences should be the same (or as similar as possible) no matter what "hat" an organization wears.