No Surprise Billing Notice and "Publicly Available"

[alexa]

HI All and Happy New Year!

We have posted the new Surprise Billing Model Notice to the benefits section of our Company intranet along with all of our other H&W compliance Notices and recently provided a link to the Notice to all US employees.

Would this satisfy the “publicly available” requirement?

Much thanks!

Lexy

[JYo]

If it is on the intranet, doesn't that mean that only certain people have access to it?  Or did you mean to say it's on your internet site?

I guess I'd need to know in what capacity you are required to provide the model notice (I.e., as a provider, an insurer, etc.) and to whom you need to provide it. Since there are a few different model notices for certain circumstances, this would be difficult to answer, but if you were speaking generally about the notice that certain health care providers and facilities are required to make publicly available, post on a public website, and provide to individuals, I don't know that an intranet site would be considered accessible.

That is just my opinion, and is not intended to be legal advice.