Workforce Bulletin

In a June 2025 decision in Purl v. United States Department of Health and Human Services, the United States District Court for the Northern District of Texas vacated the 2024 HIPAA reproductive health rule (the “Rule”), which the US Department of Health and Human Services (HHS) issued to limit how reproductive health care information could be disclosed by HIPAA regulated entities (e.g., Covered Entities and business associates), as we wrote about here and here. Now, HHS has let the August 18, 2025 appeal deadline pass without challenging the Purl decision.

HHS’s decision not to appeal Purl, however, does not relieve HIPAA regulated entities from their obligations to protect reproductive health care information. HIPAA regulated entities must still ensure that their existing HIPAA policies and procedures adequately protect PHI, including reproductive health care information, even though the protections that were in the Rule are now defunct.