justbe
Oct 27 2004, 07:59 AM
Should health care providers include a HIPPA privacy statement in their summary plan descriptions? Is it required by law? If so, what is the cite. Thank you
Steve72
Oct 27 2004, 08:06 AM
By "health care providers" I assume you mean sponsors of health plans ("Health care providers" is a defined term under HIPAA which includes doctors, hospitals, etc.)
HIPAA contains a specific requirement for a notice of privacy practices (NOPP). This is a separate requirement from the SPD.
Because the disclosure requirements are not identical, I generally advise that the NOPP be provided separately from the SPD.
Note that some have taken the position that the HIPAA amendment requires a summary of material modifications, in addition to the NOPP. I do not believe this is correct.