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be aware of, and prepared for, the security requirements demanded by the federal law. the key, under health and human services guidelines , is whether the patient voluntarily and independently chooses to use the app or wearable to transmit electronic protected health information (ephi) to a hipaa-covered
"if, on the other hand," hhs tells us, "the app was developed for, or provided by or on behalf of the covered entity — and, thus, creates, receives, maintains, or transmits ephi on behalf of the covered entity — the covered entity could be liable under the hipaa rules for a subsequent impermissible disclosure...
https://channels.theinnovationenterprise.com/articles/health-and-fitness-e-gear-brings-security-risks-in-post-new-year-days