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Reminder Privacy Notice Due by 4/14/06 for “Large” Health Plans
 
Posted on: Monday, April 10, 2006
 
Once every three years, Health Plans subject to the HIPAA Privacy Rule are required to remind plan enrollees that a Notice of Privacy Practices is available and how to request a copy. The department of Health and Human Services (HHS) recently published a FAQ reminding health plans of this requirement and provided compliance guidance.

The reminder notice can be provided* in one of three ways:

    • By sending a full copy of the Notice of Privacy Practices to employees, or
    • By mailing a reminder that the Notice is available and instructions as to
        how to request a copy, or
    • By including in a plan-produced newsletter or other publication
        information about the availability of the Notice of Privacy Practices and
        how to request a copy.

NOTE: A single reminder to the covered employee will satisfy compliance requirements for all covered dependents under a health plan.

“Large” Health Plans vs. “Small” Health Plans Compliance Dates
The three-year reminder notice will be due April 14, 2006 for Large health plans that were required to provide their initial Notices of Privacy Practices by April 14, 2003 and have not provided a notice since then. (Small health plans, which had until April 14, 2004 to provide their original Notices of Privacy Practices, will need to provide their reminders by April 14, 2007.)

Should you have any additional employee benefit questions or would like to discuss this material in detail, please don’t hesitate to call the Denman Team.