HIPAA Privacy Notice: NRECA Mailing and Co-op Distribution in Certain Cases
NRECA will mail a Notice of Privacy Practices the first week of October to participants enrolled in the NRECA medical, dental and vision plans. The Health Insurance Portability and Accountability Act of 1996 (HIPAA) requires plan sponsors like NRECA to send privacy notices to all participants enrolled in group health plans at these times:
- Upon enrollment
- At least once every three years
- Whenever the plan’s privacy practices substantially change (if sooner than three years after the last notice was sent)
NRECA last mailed the privacy notice to participants three years ago and has mailed it thereafter each month to new participants.
Note: The privacy notice is for participants’ information only. They do not need to sign or return it to NRECA.
What is the privacy notice?
The Notice of Privacy Practices explains the plan’s privacy practices and legal duties as well as participants’ rights regarding their protected health information (PHI). The notice also describes how the plan can use and disclose PHI under the HIPAA rules in instances with and without the participant’s authorization.
Find the privacy notice on the Employee Benefits website.
Privacy notice for 125 Plan health FSAs and for HRAs
HIPAA also requires cooperatives to distribute HIPAA privacy notices to the participants in their 125 Plan health flexible spending account (health FSA) and health reimbursement arrangement (HRA) plans. Co-ops should notify all current health FSA and HRA participants by September 30, 2022, or as soon as possible, of the availability of the privacy notice and where it’s located, such as on the co-op’s intranet. Participants also have the right to obtain a paper copy.
A sample privacy notice for health FSAs and HRAs is posted on the Employee Benefits website.
Note: NRECA provides the sample notice for co-ops’ convenience. The privacy officer’s name and contact information, as well as other information, must be completed with plan- and co-op-specific information that reflects your co-op’s plan operations. Because NRECA cannot give your co-op legal advice about its HIPAA obligations, we urge you to review the notice with your legal counsel before distribution.
If you have questions, contact the Member Contact Center at 866.673.2299 or contactcenter@nreca.coop.