Notice & DisclosureRecurring
HIPAA Plan Document Amendment for PHI
HIPAA; 45 CFR § 164.504(f)
Self-insured plan documents must be amended to restrict how plan sponsor uses/discloses PHI, identify firewall employees, and include certification and adequate separation provisions.
ResponsibleClient/Other TPA (compliance TPA)
Deliver ToPlan document (internal compliance)
DeadlineBefore plan sponsor can access PHI; maintain ongoing
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