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Elizabeth Brim

Elizabeth Brim provides strategic advice to clients across the health care, life sciences, digital health, and technology sectors, helping them navigate complex privacy, regulatory, and compliance issues involving health and other personal information.

Elizabeth advises clients on compliance with evolving privacy, data governance, and regulatory frameworks governing the collection, use, disclosure, and protection of health, genetic, consumer health, and other sensitive data. Her work includes counseling on HIPAA, state privacy laws, information blocking requirements, TEFCA, and other federal and state laws affecting health information, digital health technologies, and privacy compliance more broadly.

Elizabeth’s experience spans a broad range of privacy, data governance, cybersecurity, and regulatory issues arising in connection with innovative products and services, artificial intelligence and other emerging technologies, clinical trials and research initiatives, strategic transactions, and commercial arrangements. She regularly advises clients on complex issues involving data governance, privacy compliance, and the protection and exchange of health and other sensitive information.

Elizabeth also advises clients on related health care regulatory and compliance matters, including fraud and abuse, corporate practice of medicine, and other requirements affecting innovative care delivery models.

Elizabeth maintains an active pro bono practice, which includes assisting nonprofit entities with data privacy compliance and vendor contracting.

Elizabeth is an author of the American Health Law Association treatise, Pricing, Market Access, and Reimbursement Principles: Drugs, Biologicals and Medical Devices and the U.S. chapter of the Global Legal Insights treatise, Pricing & Reimbursement Laws and Regulations.

The Illinois Governor recently signed SB 2886, which expands the scope of the state’s Genetic Information Privacy Act (“GIPA”) to include “biomarker testing” and “biomarker.” GIPA currently regulates the collection, use, and disclosure of genetic testing information.

The bill defines “biomarker” as “a characteristic that is objectively measured and…

Continue Reading Illinois Expands Genetic Privacy Law to Biomarkers

The Office of Management and Budget (“OMB”) has released its 2026 Unified Agenda, which identifies regulatory actions that federal agencies expect to propose or finalize during the remainder of the year.  Below, we highlight several notable health privacy, interoperability, and data exchange rules that the Department of Health and Human Services (“HHS”) has listed for proposed or final action in 2026.  The descriptions and target dates below reflect only the agency’s stated intentions and are subject to change.

Continue Reading OMB Publishes 2026 Unified Agenda Signaling Upcoming Health Privacy and Interoperability Updates from HHS

In what continues to be a busy year for genetic privacy developments, Rhode Island has joined the growing number of states regulating direct-to-consumer (“DTC”) genetic testing with its recently enacted genetic privacy law, S 2203. With S 2203, Rhode Island is the fifth state to enact genetic privacy legislation this year, following Utah, South Dakota, Connecticut, and Vermont. 

Continue Reading Rhode Island Enacts Genetic Privacy Law

Vermont recently enacted two privacy bills to regulate health-related information. These include H.639, a genetic privacy bill regulating direct-to-consumer genetic testing companies, and the Vermont Data Privacy and Online Surveillance Act (S.71), a comprehensive privacy law that extends heightened protections to “consumer health data.” You can read our full…

Continue Reading Vermont Enacts Privacy Legislation to Regulate Health-Related Information

Following a trend from the past few years, several states have introduced bills related to genetic privacy in recent months. These bills have focused on a range of issues, including the privacy practices of direct-to-consumer (“DTC”) genetic testing companies, the national security implications of “foreign adversaries” accessing genetic information, and other topics related to genetic privacy and testing.  We summarize a subset of such recently introduced bills below.

Continue Reading Several States Introduce New Genetic Privacy Bills in Early 2026

On December 19, 2025, New York Governor Kathy Hochul vetoed the New York Health Information Privacy Act (“NYHIPA”).  While NYHIPA bore similarities to Washington’s My Health My Data Act (“MHMD”) and Nevada’s Health Privacy Law (“SB 370”), it had several provisions that would have raised novel compliance and legal questions.

Continue Reading New York Governor Vetoes Restrictive Health Privacy Law

On November 4, 2025, Senator Bill Cassidy (R-LA), chair of the Senate Health, Education, Labor, and Pensions (“HELP”) Committee, introduced the Health Information Privacy Reform Act (“HIPRA”). HIPRA seeks to extend protections similar to those provided under the Health Insurance Portability and Accountability Act of 1996, as amended, and its implementing regulations (collectively, “HIPAA”) to certain health information collected by entities not currently regulated by HIPAA. HIPRA also proposes modifications and calls for guidance related to certain existing provisions of HIPAA as well as Part 2 (related to substance use disorder medical history).

Continue Reading U.S. Senate Introduces the Health Information Privacy Reform Act

In late September, plaintiffs announced details regarding Google LLC’s (“Google”) and women’s health app developer, Flo Health Inc.’s (“Flo”) proposed settlements to resolve a class action lawsuit stemming from the Flo app’s allegedly unlawful sharing of health data with Google and others through online tracking technologies.

As part of the proposed settlements, Google agreed to pay $48 million and Flo agreed to pay $8 million, for a combined $56 million to resolve plaintiffs’ claims against these two entities.

Continue Reading Flo Health, Google Settle Class Action Privacy Lawsuit for $56 Million