The Hacking Policy Council (“HPC”) submits the following comments in response to the New York Department of Health’s proposed addition to Section 405.46 to Title 10 NYCRR (“Hospital Cybersecurity Requirements). We thank the Department of Health for the opportunity to provide input towards this important proposal. The HPC is a group of industry experts dedicated to creating a more favorable legal, policy, and business environment for security vulnerability disclosure and management, good faith security research, penetration testing, bug bounty programs, and independent repair for security. From this perspective, we recognize the importance of cybersecurity for healthcare and are broadly supportive of the Department of Health’s efforts to update sector security practices

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