Action Alert | Medicare Part D Notices and HIPAA Privacy Notices
 
 
 

Employee Benefits

 

Medicare Part D Disclosure Required by October 14

 

Entities that offer prescription drug coverage to Medicare D eligible individuals must notify those individuals whether the coverage is creditable or non-creditable. This notice must be provided each year prior to the Medicare Part D Annual Coordinated Election Period, which runs from October 15 through December 7 of each year.

 

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It May Be Time to Redistribute Your HIPAA Privacy Notice
 
Under the HIPAA Privacy Rule,covered entities must provide a Notice of Privacy Practices (or Privacy Notice) to all enrollees:
  • at the time of enrollment
  • within 60 days of a material revision to the notice
  • every three years

Due to guidance issued by the Department of Health and Human Services in January 2013, the majority of covered entities updated their Privacy Notice in September 2013 and, therefore, distributed an updated Notice to enrollees in the fall of 2013. If another Privacy Notice has not been distributed since then, now is the time to do so in order to meet the triennial requirement.

 

The Privacy Notice requirements for a health plan vary depending on whether the plan is self-insured or fully insured, and, if the plan is fully insured, whether the plan sponsor has access to PHI for plan administration purposes.

 

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