For group health plan products, can the health plan send its notice to the administrator of the group product or the plan sponsor for them to distribute to each employee enrolled in the plan?

The HIPAA Privacy Rule requires a health plan to distribute its notice to each individual covered by the plan. Health plans may arrange to have another person or entity, for example, a group administrator or a plan sponsor, distribute the notice on their behalf. However, if the other person or entity fails to distribute the notice to the plan’s enrollees, the health plan may be in violation of the Privacy Rule.

October 2018

Tags: Notice of Privacy, HIPPA