HIPAA Privacy for Employers

All Group Health Plans and Plan Sponsors receiving Protected Health Information (PHI) have certain requirements regarding the use and disclosure of this information. Many of these requirements vary based on what PHI you might receive, the funding type, and on your employees' location (because of state requirements that may be even more stringent than HIPAA). Depending on your situation, compliance obligations may include changes to vendor contracts and ERISA Plan Documents, distribution of Privacy Notices, and other administrative requirements. But regardless of the scope of the obligations, most entities covered by the new rule must now be in compliance with the requirements of the Privacy Rule.

To help familiarize you with your potential requirements under the privacy provisions of HIPAA, UniCare has prepared an information packet called HIPAA Privacy for Employers: A Comprehensive Introduction. The documents available here provide a detailed overview of the Privacy regulations and how they impact both fully-insured and self-funded groups. We have also provided example forms, compliance checklists, sample privacy notices, example plan document amendments and certifications and an exemplar business associate contract that you can use to help develop your HIPAA implementation strategy. Please see the list below for PDF versions of this information.

We have also included a copy of the HIPAA Readiness Disclosure Statement, which outlines our HIPAA readiness status.

Because your obligations under HIPAA may be significant, UniCare encourages every employer and Group Health Plan to consult your own legal counsel without delay regarding these requirements and how they would best be met. The documents available here have been prepared for you, our group clients, as helpful information only and should not be construed as legal advice. You are legally responsible for your own compliance with the HIPAA Privacy regulations and your legal counsel should be closely involved with your compliance activities.

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• HIPAA Privacy for Employers: A Comprehensive Introduction
• Attachment 1 - Sample Group Health Plan Notices of Privacy Practices
• Attachment 2 - Sample Template for a Business Associate Agreement
• Attachment 3 - Sample Plan Sponsor's Summary Health Information Request
• Attachment 4 - Extract of Section 164.504 (f) of the Privacy Regulation to Include a Sample Compliance Checklist
• Attachment 5 - Sample Plan Sponsor's Amendment to Plan Documents Required for Access to PHI
• Attachment 6 - Sample Plan Sponsor Certification of Amendment to Plan Documents
• UniCare HIPAA Readiness Disclosure Statement