Texas Court Vacates 2024 HIPAA Reproductive Health Privacy Rule

On June 18, 2025, a Texas federal court vacated nearly all provisions of the 2024 Department of Health and Human Services (HHS) HIPAA Privacy Rule designed to protect reproductive health care information, including abortion, contraception, and IVF data. The court ruled that HHS exceeded its statutory authority by creating special protections for reproductive health information without explicit congressional authorization and improperly limited state child abuse reporting laws. Key objections included the Rule's redefinitions of terms like "person" and "public health," and its requirement that covered entities attest to the lawful use of reproductive health information before disclosure, which the court found unworkable. This decision effectively restores the pre-2024 HIPAA framework, allowing disclosures of protected health information for law enforcement and public health purposes under existing conditions and state laws, which may be more or less stringent. The ruling has nationwide impact, eliminating enhanced federal privacy protections for reproductive health data, though covered entities remain subject to applicable state privacy laws. It remains uncertain whether the decision will be appealed or if states will enact their own privacy protections in response.