Waaaay back in the dark ages, I recall sending HIPAA notices to our staff and setting up a system to provide HIPAA certificates. Then we outsourced and I stopped paying as close attention as I should have.

Now I have a new job and I'm getting all their compliance issues settled. I can't recall if there is a requirement to communicate HIPPA information to our new hires (similar to the initial COBRA notices). Any help?

Thanks,

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Steve Moss
Benefits Administrator

HIPAA certificates are automatic under Sec 9801 upon the termination of coverage. It therefore is a requirement of the former employer, and has no bearing on a new employer. There is a good HIPAA Q&A in the Q&A section of this Web site.

Yes, I realize that a "Certificate of Creditable Coverage" is required for staff who terminate. We're okay with that. I want to know if a notification is required of our HIPAA policy to new staff.

I checked out the Q&A before I posted the question. I didn't see any mention of such a notice. I also checked my Spencer CD. Couldn't find it there either.

[This message has been edited by SMoss (edited 10-21-1999).]

The only initial HIPAA notice I'm aware of is the one advising employees of the special enrollment periods. This notice has to be provided "on or before the time an employee is offered the opportunity to enroll in a group health plan." Usually you'd put it in your annual open enrollment materials. There's model language in the regs.

Try HIPAA Q&A 26. You stated that these were new hires. Why are you trying to assume the responsibility of the old employer?. Q&A is an accurate quoting of the applicable HIPAA requirement.