Privacy Regulation Compliance Date Looms Closer for Small Group Health Plans


As small group health plans begin  the 2004 plan year, they must consider how the privacy regulations will apply to them.  The privacy regulations will generally apply to small group health plans (plans that have less than $5,000,000 in receipts) on April 14, 2004. The Center for Medicare and Medicaid Services indicated last fall that health flexible spending accounts are exempt from HIPAA's standard electronic transaction requirements, but it did not exempt such accounts from HIPAA privacy.  The privacy regulations require changes in a group plan's agreements with all of its vendors, third party administrators, network providers, large case management, utilization review, subrogation vendors, etc.

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