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Last Chance for Compliance HIPAA Privacy for Small Health Plans
April 14, 2004 is the approaching deadline for small health plans ' plans that have annual total premiums (both employer and employee contributions) of $5,000,000 or less ' to comply with the privacy regulations under the Health Insurance Portability and Accountability Act (HIPAA).
The deadline will have its greatest impact on mid-size and small law firms who did not have to comply with last year's deadline that applied to large health plans. The amount of work required for a mid-size or small firm to comply will depend on whether the employer has any self-funded plans and the extent to which the firm receives protected health information.
The April 14, 2004 deadline, however, will also impact many large firms. Many large firms sponsor small health plans (eg, dental plans, vision plans, health flexible spending arrangements, and employee assistance plans) that are not yet compliant. All firms, regardless of size, should review all of their health plans to determine compliance with the HIPAA privacy regulations.
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