compliance dates and effective dates (HIPAA)

For HIPAA regulations, the compliance date is the date on or before which a covered entity must meet the requirements of a standard (rule), implementation specification or modification.

Under HIPAA, this is usually 24 months after the effective date (defined below) of a final rule for large entities, and 36 months for small ones. The dividing line between "large" and "small" for this purpose is $5M in annual revenues.

For subsequent modifications of "final" rules, the compliance date must be at least 180 days after the effective date, but could be longer for small entities or where the change is considered particularly complex or difficult to implement.

The effective date of any change is usually 60 days after its official publication in the Federal Register.

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