Under HIPAA’s privacy rules, small health plans must issue a reminder about the notice and how to get it at least once every three years. Therefore, those small plans that haven’t issued the notice since the April 2004 compliance date must do so by the April 14 deadline.
Small plans are considered as those with less than $5 million in annual “receipts,” meaning premiums for insured plans and claims for self-funded plans. Fully insured plans do not have to provide privacy notices.
The U.S. Department of Health and Human Services (DHHS) says the plans have a choice in issuing the reminder, which include the following methods:
- Resend their full Notice of Privacy Practice (NPP),
- Mail a separate reminder regarding the NPP’s availability and how to obtain a copy; or
- Include the information in a plan-produced newsletter or other publication.
For general information on HIPAA, visit the DHHS Web site at http://www.hhs.gov/ocr/hipaa/ .