tci Medicare Compliance & Reimbursement - 2004 Issue 21

Health Plans: Not All Group Plans Are Exempt From HIPAA

Only some provisions are mitigated for fully insured plans.Group health plans may not need to satisfy all of the requirements of the privacy rule if they are fully insured, according to the HHS Office of Civil Rights, since the mainstay of responsibility belongs to the health insurance issuer or health maintenance organization contracted by the plan. "Fully insured group health plans that do not create or receive protected health information other than summary health information and enrollment or disenrollment information are not required to have or provide a notice of privacy practices," OCR explains.However, despite...

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