When the Health Insurance Portability and Accountability Act (“HIPAA”) was enacted in 1996, the smart phone was not even a gleam in Steve Jobs’ eye, and mobile health apps and cloud computing did not exist. Even though the primary regulations implementing and amending HIPAA became effective in 2003, 2005, and 2013, regulators and lawmakers continue to play catch-up, striving to apply HIPAA’s regulatory framework to an ever-evolving technology landscape.