Published March 7, 2025
On March 7, 2025, EPPC Scholar Eric Kniffin submitted a public comment in opposition to HHS’s proposed “HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information.
Kniffin emphasizes in his comment that this HHS proposal would strengthen and reinforce HHS’s 2004 final HIPAA Reproductive Health Care Privacy Rule, which EPPC scholars last year warned the Biden Administration unlawfully interferes with law enforcement efforts to enforce laws protecting unborn life and protecting children from harmful “gender transition” procedures.
The EPPC scholar’s comment states:
[The proposed HIPAA Security Rule], which was published in the final days of the Biden Administration, incorporates by reference the Biden Administration’s pro-abortion and pro-gender transition HIPAA Reproductive Health Care Privacy Rule. This rule has been, from the start, clearly illegal. It is the subject of at least two lawsuits and has been enjoined once already. It is also critical that HHS recognize that the proposed HIPAA Security Rule, by virtue of its relationship to the HIPAA Reproductive Health Care Privacy Rule, conflicts with several of President Trump’s early executive orders.
For all these reasons, I urge HHS to promptly withdraw the proposed HIPAA Security Rule and not to reconsider it until HHS’s unlawful HIPAA Reproductive Health Care Privacy Rule is eliminated.
The public comment also notes that the State of Tennessee attached EPPC’s public comment opposing the HIPAA Reproductive Health Care Privacy Rule as an attachment to its summary judgment motion asking a federal court to find the rule unlawful.
Eric Kniffin is a fellow at the Ethics and Public Policy Center, where he works on a range of initiatives to protect and strengthen religious liberty as part of EPPC’s Administrative State Accountability Project.
