On August 15, 2025, the City of Columbus, Ohio, the City of Madison, Wisconsin, and Doctors for America filed a Notice of Appeal in the case Carmen Purl, M.D., et al. v. U.S. Department of Health and Human Services, in the Northern District of Texas, Amarillo Division, under Civil Action No. 2:24-cv-00228-Z.
What happened
The appeal challenges two prior rulings: the June 18, 2025 order that granted the plaintiffs’ Motion for Summary Judgment and denied the defendants’ Motion to Dismiss for Lack of Jurisdiction, and the July 3, 2025 order that further addressed issues arising from the June decision.
The notice states that the appellants are filing this appeal to protect their right to seek review of these decisions, contingent upon the outcome of a separate appeal they filed earlier on June 13, 2025, which contests the April 15, 2025 denial of their Motion to Intervene in the case.
What was said
According to the Memorandum for the ruling, “The 2024 Rule benefits those whose information it protects. It is not designed to benefit healthcare providers. Instead, it instructs them to keep specified information confidential so patients benefit.”
The bigger picture
The ruling matters because it vacates most of HHS’s 2024 HIPAA ‘Reproductive Health Care Privacy’ rule nationwide, stripping away new limits that would have blocked covered entities from disclosing reproductive protected health information (PHI) for investigations or prosecutions where the care was lawful, reopening channels for state actors to seek patient records through the older ‘required by law’ and law-enforcement exceptions.
For patients, that rollback heightens the risk that abortion- or gender-related care could be traced through medical records, chilling care-seeking and cross-state travel for lawful services. For healthcare organizations, operational and legal exposure increase immediately, and compliance teams must unwind planned Notice of Privacy Practices changes tied to the 2024 rule.
It also includes recalibrating disclosure workflows for subpoenas and warrants, and update training, consent, and incident-response playbooks to reflect pre-rule HIPAA standards and any applicable state ‘shield’ or cooperation limits. All of that unfolds while cities and provider groups seek appellate review, and Columbus, Madison, and Doctors for America noticed an appeal.
See also: HIPAA Compliant Email: The Definitive Guide (2025 Update)
FAQs
What is the HIPAA Reproductive Health Care Privacy Rule?
The rule, finalized in April 2024 by the U.S. Department of Health and Human Services (HHS), added extra privacy protections for reproductive health information.
Why was the rule created?
The rule was created after the Dobbs v. Jackson Women’s Health Organization decision in 2022, which overturned Roe v. Wade. The goal was to protect patients’ sensitive health information from being accessed for investigations or prosecutions in states where certain reproductive services are restricted or criminalized.
Which parts of the rule were left intact?
Only provisions tied to substance use disorder (SUD) disclosures in Notices of Privacy Practices (NPPs) remained in effect. Most protections specific to reproductive health data were struck down.
Kirsten Peremore
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