Employee Handbook

14.28 Disclosures to Plan Sponsor

14.28.1 Policy Statement

The Health Plan may not disclose protected health information (PHI) to the plan sponsor except in specific situations recognized by HIPAA.

14.28.2 Policy Interpretation and Implementation

Definition of Plan Sponsor

The term “plan sponsor'' means (i) the employer in the case of an employee benefit plan established or maintained by a single employer, (ii) the employee organization in the case of a plan established or maintained by an employee organization, or (iii) in the case of a plan established or maintained by two or more employers or jointly by one or more employers and one or more employee organizations, the association, committee, joint board of trustees, or other similar group of representatives of the parties who establish or maintain the plan.

 

 

Permitted Disclosure to Plan Sponsor for Settlor Functions

Summary health information may be disclosed to the plan sponsor for:

Obtaining premium bids for providing health insurance coverage under the Health Plan; and

Modifying, amending or terminating the Health Plan.

 

 

Summary Health Information

Summary health information is information that summarizes the claims history, expenses, or types of claims by individuals for whom the Plan Sponsor has provided health benefits under the Health Plan.

 

 

Permitted Disclosure to Plan Sponsor for Plan Administration Functions

To the extent described in the plan documents and notice of privacy practices, the Health Plan may disclose PHI to the plan sponsor necessary to perform plan administration activities such as:

  • Quality assurance;
  • Claims processing;
  • Auditing; and
  • Monitoring and managing carve-out plans like vision and dental.

 

 

Enrollment Functions

These restrictions do not affect the plan sponsor's ability to perform enrollment functions on behalf of its employees.

 

 

 

Record Retention

A copy of all HIPAA covered information and any revisions shall be maintained for a period of at least six (6) years. Such retention may be in printed or electronic format, or both.

 

 

Privacy Officer

The Privacy Officer is responsible for the development and implementation of the HIPAA policies and procedures. The Privacy Officer is also the contact person for any questions or complaints regarding HIPAA. Questions or concerns about HIPAA rights should be directed to the Privacy Officer during regular business office hours Monday through Friday, except holidays, at (651) 696-6280.

 

 

Violations

Violations of this policy will be subject to discipline.