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HIPAA, HRA and privacy notices

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Along with considering other points of law and each person getting its lawyer's advice, one might revisit an assumption that the employer never receives protected health information.

For the non-insured health-reimbursement arrangement, does the employer (perhaps in a role as the plan's administrator or other named fiduciary) have a legal right or power to overrule the third-party administrator's claims-processing decision?  If so, how does such a decision-maker or reviewer evaluate a claim without at least receiving protected health information?

And which person engaged the TPA service provider?  Is that person a fiduciary?  What information does the person consider to evaluate whether it remains prudent to continue the TPA's engagement?


Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania



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