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Keywords

lawsuitappealregulationHIPAAdue processappellant

statuteregulationHIPAAdue processappellant

Related Cases

South Carolina Medical Ass’n v. Thompson, 327 F.3d 346

Facts

Appellants, including the South Carolina Medical Association and several individual doctors, filed a lawsuit seeking to declare unconstitutional several provisions of HIPAA. They argued that HIPAA violated the non-delegation doctrine, that the Privacy Rule exceeded HHS's authority, and that HIPAA's non-preemption of more stringent state laws was unconstitutionally vague. The district court dismissed the action, leading to the appeal.

Recognizing the importance of protecting the privacy of health information in the midst of the rapid evolution of health information systems, Congress passed HIPAA in August 1996. HIPAA's Administrative Simplification provisions, sections 261 through 264 of the statute, were designed to improve the efficiency and effectiveness of the health care system by facilitating the exchange of information with respect to financial and administrative transactions carried out by health plans, health care clearinghouses, and health care providers who transmit information in connection with such transactions.

Issue

The main legal issues were whether HIPAA impermissibly delegated legislative power to HHS, whether the Privacy Rule exceeded HHS's authority, and whether HIPAA's non-preemption provision was unconstitutionally vague.

The first issue is whether HIPAA violates the non-delegation doctrine. Appellants argue that 1) HIPAA violates the non-delegation doctrine by authorizing HHS to promulgate the regulations at issue in the absence of an intelligible principle from Congress; 2) the Privacy Rule exceeds the scope of authority granted to HHS under HIPAA; and 3) HIPAA's non-preemption of 'more stringent' state privacy laws is unconstitutionally vague, in violation of the Due Process Clause of the Fifth Amendment.

Rule

The court applied the non-delegation doctrine, which requires that Congress provide an intelligible principle when delegating legislative power to an agency. It also examined whether the regulations were reasonably related to the purposes of the enabling legislation.

The court has outlined an approach to determining the difference between prohibited delegation and necessary cooperation between coordinate branches: 'In determining what [Congress] may do in seeking assistance from another branch, the extent and character of that assistance must be fixed according to common sense and the inherent necessities of the governmental coordination.'

Analysis

The court found that HIPAA contained intelligible principles guiding HHS's actions, thus satisfying the non-delegation doctrine. It concluded that the Privacy Rule was consistent with HIPAA's objectives and that the scope of the regulations was appropriate, including both electronic and non-electronic health information. The court also determined that the non-preemption provision provided sufficient clarity to avoid vagueness challenges.

In light of this guidance, we conclude that HIPAA also contains the requisite intelligible principle necessary to survive a non-delegation challenge. Specifically, there are at least three sources within HIPAA that provide intelligible principles outlining and limiting the Congressional conferral of authority on HHS.

Conclusion

The court affirmed the district court's dismissal of the suit, concluding that HIPAA and its regulations were constitutional and did not violate the non-delegation doctrine or due process.

For these reasons, we conclude that HIPAA does not violate the non-delegation doctrine.

Who won?

The United States Department of Health and Human Services prevailed in the case because the court upheld the constitutionality of HIPAA and its regulations, finding that they did not violate the non-delegation doctrine or due process.

The court ultimately upheld the constitutionality of HIPAA and its associated regulations.

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Shannon v. McNulty, 718 A.2d 828

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Brown v. Belinfante, 252 Ga.App. 856, 557 S.E.2d 399, 01 FCDR 3654

Burditt v. U.S. Dept. of Health and Human Services, 934 F.2d 1362, 60 USLW 2075, 33 Soc.Sec.Rep.Serv. 566, Med & Med GD (CCH) P 39,476

St. Agnes Hosp. of City of Baltimore, Inc. v. Riddick, 748 F.Supp. 319, 59 USLW 2206