In Moreland v. Austin. 284 Ga. 730 (670 SE2d 68) (2008), the Supreme Court of Georgia clarified that Health Insurance Portability and Accountability Act of 1996 (HIPAA) applies to ex parte communications between defense counsel and heathcare providers, that HIPAA is more stringent than Georgia law, and that it therefore "preempts Georgia law with regard to ex parte communications between defense counsel and plaintiff's prior treating physicians because HIPAA affords patients more control over their medical records when it comes to informal contacts between litigants and physicians." Id. at 733. The Supreme Court instructed: "Thus, in order for defense counsel to informally interview plaintiff's treating physicians, they must first obtain a valid authorization, or court order or otherwise comply with the provisions of 45 CFR 164.512 (e)." Id.