FTC HBNR 2024 Final Rule Amendments (effective 29 July 2024 + 25 April 2025 for delayed elements). KEY EXPANSIONS: (1) MOBILE HEALTH APPS + CONNECTED DEVICES: explicit coverage of consumer-facing health apps + wearables + fitness trackers + sleep monitors + smart scales + connected medical devices even if not marketed as PHR; (2) NEW BREACH DEFINITION: explicitly includes UNAUTHORIZED DISCLOSURE to (a) ADVERTISING/MARKETING networks; (b) 3rd-party SDKs (e.g. Meta Pixel + Google Tag Manager + analytics SDKs) collecting health information without user authorization; (c) DATA BROKERS; (d) CROSS-APP TRACKING of health information; (e) RE-IDENTIFICATION of supposedly de-identified data; (3) REPRODUCTIVE HEALTH DATA: heightened sensitivity + alignment with post-Dobbs (June 2022) state-law abortion-restriction concerns + data subpoena risks; period-tracker + fertility apps + pregnancy apps + reproductive-health-clinic-finder apps in scope; (4) UPDATED PHR IDENTIFIABLE HEALTH INFORMATION definition: clarifies mobile + sensor + sensor-derived inferred data; (5) HEALTHCARE PROVIDER NEW DEFINITION: aligns with FTC enforcement priorities; (6) TPSP CLARIFICATIONS. ENFORCEMENT TARGETING (2024-2025): FTC has prioritized cases involving (a) advertising-pixel disclosures of health data (e.g. GoodRx + BetterHelp + Premom + Easy Healthcare + others); (b) reproductive-health data privacy; (c) mental health app disclosures.
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