The HIPAA Privacy Rule requires every health plan to provide a
Notice of Privacy Practices (NPP) to all plan participants.
Self-insured plans (and fully insured plans that obtain protected
health information from participants) must provide the NPP to
insureds at the time of enrollment and within 60 days of any
material revision to the NPP.
Health plans are also required to remind participants of the
existence of their NPP, and tell them how they can obtain a copy of
it, no less often than once every three years.
The HIPAA Omnibus Final Rule, released in January 2013, modified
requirements for NPPs and required all health plans to update
theirs by September 23, 2013. Plans then had to notify all
participants of the revisions within 60 days thereafter, which for
procrastinators was on or about November 22, 2013.
Many health plans routinely include their current NPP in their
annual open enrollment materials, which obviates the need to
provide a three-year reminder. However, any plan that has not
provided its NPP to all participants within the past three years
should be sure to do so before the 2016 anniversary of the date it
sent out its 2013 revision.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
