«The Department of State already concluded that the Indian Point relicensing application is
inconsistent with New York's long - standing Coastal Management Program
requirements and will continue to
use this program to protect New York's coastline.
The majority of commenters on this topic, however, argued that a signed acknowledgment would be administratively burdensome,
inconsistent with the intent of the Administrative Simplification
requirements of HIPAA, impossible to achieve for incapacitated individuals, difficult to achieve for covered entities that do not have direct contact with patients,
inconsistent with other notice
requirements under other laws, misleading to individuals who might interpret their signature as an agreement, inimical to the concept of permitting
uses and disclosures without authorization, and an insufficient substitute for authorization.
Comment: A few commenters asserted that the
requirement to include a statement in which the patient acknowledged that information
used or disclosed to any entity other than a health plan or health care provider may no longer be protected by federal privacy law would be
inconsistent with existing protections implemented by IRBs under the Common Rule.