Reminder: Distribute HIPAA Privacy Practices Notice by April 14
If your cooperative sponsors a CBA-administered health flexible spending account (health FSA) or health reimbursement arrangement (HRA), remember that HIPAA requires distribution of the Notice of Privacy Practices to plan participants on three separate occasions:
- upon enrollment in the plan
- at least once every three years
- whenever the plan’s privacy practices substantially change, if sooner than the three-year period
Co-ops should notify all current health FSA and HRA participants by April 14, 2016 of the availability of the privacy notice and where it’s located, such as the co-op’s intranet. Participants also have the right to obtain a paper copy.
Sample privacy notice online
A sample privacy notice is posted on the Employee Benefits website. Go to My Benefits > Help & Resources > Documents for Coops > HIPAA Resources. The document, “SAMPLE – HIPAA Notice of Privacy Practices” can be customized for your co-op’s needs.
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.