Introduction On 10 December 2020, the Office of Civil Rights (OCR) for the federal Department of Health and Human Services (the Department) issued Proposed Modifications to the HIPAA Privacy Rule to Support, and Remove Barriers to, Coordinated Care and Individual Engagement (the Proposed Rule). 1 The Proposed Rule comes nearly two years after OCR issued a Request for Information from stakeholders regarding the ways that HIPAA could be modernized to support coordinated, value-based care. 2 OCR includes numerous proposed changes to the HIPAA Privacy Rule intended to eliminate regulatory barriers for purposes of fostering care coordination and the shift to value-based care models, including clarifying the scope of care coordination for disclosures of protected health information (PHI) under the health care operations and treatment exceptions, and creating an exception to the minimum necessary standard for disclosures related to care coordination and case management.