Sentences with phrase «other commenters argued»

Other commenters argued that the proposal would have given too much discretion to the record holders to withhold evidence without having sufficient expertise or information on which to make such judgments.

Other commenters argued more generally that the Secretary's authority was limited to information in electronic form only, not information in any other form.

Other commenters argued that a complete exemption for workers» compensation carriers was inappropriate.

Other commenters argued that disclosure of protected health information for judicial and administrative proceedings should require a court order and / or judicial review unless the subject of the information consents to disclosure.

Other commenters argued that imposing a new requirement of prior judicial process would compromise the time - sensitive nature of many investigations.

Other commenters argued for the deletion of the criterion on grounds that requiring researchers to contact patients whose records were used for archival research would be unduly burdensome, while adding little to the patient's base of information.

Similarly, other commenters argued that the «reasonably aware» provision gives too much discretion to institutions to report private loans.

Other commenters argued that the Department's estimated investor losses from the proposed 60 - day delay were overstated because they were derived from the 2016 RIA, which these commenters contend overestimated net investor gains.

Not exact matches

On the other hand, commenters supporting the proposed 60 - day delay or a longer or indefinite delay argued that such delay would be appropriate, because it would provide sufficient time for the Department to complete its review of the Rule and PTEs in conformance with the President's Memorandum without issuing a series of extensions that could create market frictions due to uncertainty regarding whether the Department would ultimately leave the Rule in place, revise it, or rescind it.

Although many commenters supported a 60 - day delay for this purpose, others argued that a much longer period is needed (e.g., a 1 - year delay or an indefinite extension terminating 60 or more days after completion of the examination required by the President's Memorandum).

Other commenters agreed with using 10 years for certificate or diploma programs, but argued for extending the amortization period to 25 years for graduate, doctoral, and first professional degree programs.

In recent discussion of the Weblog 2007 Awards, several commenters at other blogs have argued that our criticisms of the Mannian parlor tricks have been «thoroughly refuted and discarded by climatologists, published in a credible journal»; that «other professionals in the field who also have «looked in great detail at the problem at hand» and have come to the conclusion that rather than McIntyre's findings being «valid and relevant», they instead have found them to be «without statistical and climatological merit»; that CA «fluffed on the whole hockey stick thing».

Like many other commenters, Martin argued that more time is needed.

Some commenters argue that the length of the patent vetting process has created so much frustration that some inventors aren't even bothering to file while others opine that companies are cutting IP budgets due to the economy, so they aren't filing as much.

Comment: Some commenters argued that, while a court order should be required, the standard of proof should be something other than «probable cause.»

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: Many commenters argued that proposed § 164.510 (f)(2) should be deleted because it would permit law enforcement to engage in «fishing expeditions» or to create large data bases that could be searched for suspects and others.

Comment: Numerous commenters argued that the proposed coverage of any information other than that which is transmitted electronically and / or in a HIPAA transaction exceeds the Secretary's authority under section 264 (c)(1) of HIPAA.

This commenter argued that this would lead to different standards for the protection of other kinds of individually identifiable health information used in research that will fall outside of the scope of the final rule.

A few commenters argued that effective law enforcement requires early access to as much information as possible, to rule out suspects, assess severity of criminal acts, and for other purposes.

Other commenters believed accessible information should be more limited; for example, some commenters argued that accessible information should be restricted to only information used to make health care decisions.

Response: We agree with the commenters who argued that the final rule should permit the documentation of IRB or privacy board approval to be signed by someone other than the chair of the board.

One commenter asserted that dishonest health care providers and others should not be able to withhold their records by arguing that state subpoena and criminal discovery statutes compelling disclosure are preempted by the privacy regulation.

Comments: Many commenters argued that training, as well as all of the other administrative requirements, are too costly for covered entities and that small practices would not be able to bear the added costs.

Comment: Some commenters argued that the privacy rule should defer to other laws that regulate the disclosure of information to employers and workers» compensation carriers.

Comment: One commenter representing church plans argued that the regulation should treat such plans differently from other group health plans.

Comment: One commenter argued that the term «transaction» is generally understood to denote a business matter, and that the NPRM applied the term too broadly by including hospital directory information, communication with a patient's family, researchers» use of data and many other non-business activities.

These commenters also questioned the definition of «loan costs» in comment 37 (l)(1)(i)-1 which defines loan costs as costs disclosed under § 1026.37 (f), arguing that the amount disclosed would be overstated because the definition does not account for credits provided by the creditor, mortgage broker, seller, or other party.