The U.S. Department of Health and Human Services (HHS) has announced the appointment of Paula M. Stannard as Director of the Office for Civil Rights (OCR). Serving as the Department’s chief officer for these matters, Stannard will oversee implementation, compliance, and enforcement of Federal health information privacy, security, breach notification rules under the Health Insurance Portability and Accountability Act (HIPAA), as well as civil rights, conscience protections, and religious freedom laws within the HHS’ jurisdiction. She will report directly to HHS Secretary Robert F. Kennedy Jr.
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Stannard Has an Extensive Background in Health Policy and Law
Director Stannard has extensive experience serving in Federal and state government, as well as the private-sector expertise.
- State Leadership
Most recently, Stannard served as Chief Legal Counsel for the Montana Department of Public Health and Human Services, where she oversaw the Office of Legal Affairs. There, she advised the agency on a broad spectrum of legal matters, including compliance with laws governing the department’s programs.
- Federal Service
Her federal career includes advisory roles under two administrations. She acted as Senior Counselor to Secretaries Tom Price and Alex Azar during the Trump administration and served as both Acting General Counsel and Deputy General Counsel under President George W. Bush’s administration.
- Private Practice
Stannard has over 16 years of legal experience. She practiced as counsel in the Health Care Practice Group at Alston & Bird, LLP, and as a litigation associate at Skadden, Arps, Slate, Meagher, and Flom.
This blend of experience positions her to enforce HHS policies she had a hand in shaping during her previous tenure.
Priorities for OCR Under Stannard’s Leadership
Director Stannard’s appointment comes at a critical time for the HHS OCR, with multiple pressing issues on the table that concern health information privacy and patient rights. Here’s a detailed look at the key challenges expected to shape her tenure:
1. Proposed Updates to the HIPAA Security Rule
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- OCR is currently evaluating significant modifications to the HIPAA Security Rule. These proposed changes aim to strengthen the protection of electronic protected health information (ePHI) in light of advancements in technology and the changing cybersecurity landscape. Stannard is expected to play a key role in determining the next steps after public comments on the proposal closed in March 2025.
2. The Role of Artificial Intelligence (AI) in Healthcare
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- The May 2025 implementation of updates under the Affordable Care Act’s Section 1557 will require entities to mitigate risks of discrimination when using AI-powered decision-support tools. Stannard will oversee the enforcement of these regulations.
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3. Review of Online Tracking Technologies by Covered Entities
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- Under Stannard’s guidance, OCR may revisit its position on third-party tracking technologies on unauthenticated websites. These technologies have raised questions about compliance with HIPAA’s definition of protected health information. Stannard will likely weigh in on how to move forward in light of court-ordered vacatur of previous restrictions.
