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The Department of Health and Human Services (“HHS”) recently announced guidelines for the application of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) to audio-only telehealth encounters following the end of the declaration of the COVID-19 public health emergency (“PHE”). As reported here at the beginning of the Covid-19 pandemic, the HHS Office of Civil Rights (“OCR”) announced that it would exercise discretion in enforcing HIPAA regulations so long as a covered entity…