On April 27, 2023, the Washington State governor signed into law the My Health My Data Act or the MHMDA. In spite of the onerous and at times confusing requirements of the MHMDA, the Washington Attorney General (AG) has only published a short set of Frequently Asked Questions to help address some of this uncertainty.  Nevertheless, most of the law’s provisions take effect on March 31, 2024, meaning that, at this point, companies have a very short runway to meet their obligations and brace for the private right of action allowed for under the act.   With this in mind, we have prepared this brief recap of the law and the steps companies should consider as they gear up for compliance. Our more detailed summary of the MHMDA is available in our original insight, and we will also be releasing a series of short FAQs over the coming weeks to help companies prepare.

On April 27, 2023, the Washington state governor signed into law the My Health My Data Act, also known as the MHMDA. The majority of the law’s provisions will take effect on March 31, 2024, providing companies with one (short) year to prepare to meet their obligations and brace for the private class action litigation allowed under the act.   Even with all of the other state laws that have recently passed or are waiting in the wings, the MHMDA stands out in its broad scope, confusing and/or onerous obligations and potential risk for organizations.  Companies should not put compliance with its mandates on the back burner. With this in mind, we have prepared a summary of key compliance requirements of the MHMDA.  We will continue to examine the law in more depth and track guidance and other developments as they emerge.