little more than a year ago, many of us were frantically copying Privacy Notices, completing HIPAA training and tweaking our privacy policies. While some commentators predicted mass chaos after April 14, 2003 as a result of the HIPAA privacy requirements, the intervening year has been manageable, thanks to the diligent efforts of the health care community in preparing for compliance. HIPAA is not just a test that a covered entity passed or failed on April 14, 2003, however; compliance is an ong