HHS's 2024 Rule on Reproductive Health Information Vacated by Federal Court

Strategic Insights -

The US Department of Health and Human Services' ("HHS") 2024 Rule, which provided specific protections for reproductive health information under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), has been largely vacated by a federal court. Judge Matthew J. Kacsmaryk of the US District Court for the Northern District of Texas ruled on June 18, 2025, that HHS exceeded its statutory authority in creating special protections for certain medical procedures. The court's decision in Purl v. U.S. Department of Health and Human Services reinstates the HIPAA framework in place before the 2024 Rule, allowing disclosures of protected health information for law enforcement and public health purposes without the need for an attestation.

Key Takeaways:

  • The 2024 Rule, which provided specific protections for reproductive health information under HIPAA, has been largely vacated by a federal court.
  • Judge Matthew J. Kacsmaryk ruled that HHS exceeded its statutory authority in creating special protections for certain medical procedures.
  • The court's decision nullifies the 2024 Rule, except for technical provisions unrelated to reproductive health information.
  • The verdict reinstates the HIPAA framework in place before the 2024 Rule, allowing disclosures of protected health information for law enforcement and public health purposes.
  • Under the reinstated framework, disclosures are not mandatory and may be subject to state law protections more stringent than HIPAA.
  • Judge Kacsmaryk's ruling is effective nationwide, but HHS can seek a stay or pursue an appeal to the Fifth Circuit.
  • Purl v. U.S. Department of Health and Human Services is the relevant case that led to the vacating of the 2024 Rule.
  • Ms. Lisa Prather, a lawyer at Katten Muchin Rosenman LLP,'s contact information is 312-577-8469 or brook.radford@katten.com.
  • The ruling has significant implications for the use and disclosure of reproductive health information under HIPAA.

Statistics:

  • 2024: The year in which the US Department of Health and Human Services implemented the new privacy rule under HIPAA.
  • June 18, 2025: The date on which Judge Matthew J. Kacsmaryk issued the opinion largely vacating the 2024 Rule.
  • Nullified: The 2024 Rule's status after the court's decision.
  • HIPAA: The Health Insurance Portability and Accountability Act of 1996 framework reinstated by the court's decision.
  • Effective: Judge Kacsmaryk's ruling is effective nationwide.

Sources:

  • Purl v. U.S. Department of Health and Human Services
  • US Department of Health and Human Services
  • Judge Matthew J. Kacsmaryk
  • Mondaq Ltd. (2025)
  • Katten Muchin Rosenman LLP