The Increasing Role of the Federal Trade Commission in the Poaching of PHI - A Discussion of Better Help, GoodRx, and Flo


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Title: The Increasing Role of the Federal Trade Commission in the Poaching of PHI - A Discussion of Better Help, GoodRx, and Flo


Presenter: Rachel V. Rose, JD, MBA, principal with Rachel V. Rose – Attorney at Law, P.L.L.C., Houston, TX


Cybersecurity risk management and the potential for enforcement actions is not diminishing. An area of increasing interest by the Federal Trade Commission, the United States Department of Justice, and Congress is third parties taking sensitive data (especially by social media and search engine giants), including protected health information, without obtaining affirmative patient/consumer consent and benefiting financially. The U.S. Department of Health and Human Services, the agency tasked with enforcing HIPAA, also plays a critical role. The purpose of this presentation is to address different federal government initiatives, recent enforcement actions and incidents, and risk mitigation.



  1. Learn about the differences between various laws and the implications for liability in relation to not obtaining the appropriate patient/consumer consent before using sensitive information for sales and marketing purposes.
  2. Appreciate the various initiatives, incidents, and enforcement actions taken by private entities in disclosing potential breaches, as well as different federal government enforcement actions.
  3. Glean risk management tools to incorporate into compliance programs.


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Rachel V. Rose, JD, MBA, principal with Rachel V. Rose – Attorney at Law, P.L.L.C., Houston, TX


Ms. Rose has a unique background, having worked in many different facets of healthcare, securities, and cybersecurity, as well as international law and business throughout her career. Her practice focuses on a variety of cybersecurity, healthcare, and securities law issues related to industry compliance and transactional work, as well as representing plaintiffs in Dodd-Frank/False Claims Act whistleblower claims.


In addition to being extensively published and a sought-after presenter and quoted expert, Ms. Rose holds an MBA with minors in healthcare and entrepreneurship from Vanderbilt University, and a law degree from Stetson University College of Law, where she graduated with various honors, including the National Scribes Award and The William F. Blews Pro Bono Service Award.


Ms. Rose is licensed in Texas and is admitted to practice before all State Courts, as well as the United States Supreme Court, the District Court for the District of Colombia, and all four Federal Court Districts in the State of Texas. She is a Fellow of the Federal Bar Association. Currently, she is the Chair of the Federal Bar Association’s Government Relations Committee, a board member of the Federal Bar Association's Qui Tam Section, the co-editor of the American Health Lawyers Association’s Enterprise Risk Management Handbook for Healthcare Entities (2nd Edition), as well as a co-author of the books The ABCs of ACOs and What Are International HIPAA Considerations?


She has been named consecutively to the Texas Bar College, the National Women Trial Lawyers Association's Top 25, and Houstonia Magazine's Top Lawyers for healthcare. In 2019, she was also named to the National Trial Lawyers Association's Top 100, as well as 1st Healthcare Compliance's 2019 Top Presenter. Ms. Rose is also an Affiliated Member with Baylor College of Medicine’s Center for Medical Ethics and Health Policy, where she teaches bioethics. See www.rvrose.com for additional information.