Cate

Thank you, Brian, I appreciate very much your response!

I'm sorry, I didn't get a notification that anyone had commented, I appreciate you taking the time. Yes, this is a situation where a parent/subscriber has dependent coverage on an adult child, and called into us (TPA) to ascertain if the child was still on the plan. I'm not sure why the parent called in. And I agree it is strange that a subscriber doesn't know who is on their plan. Perhaps they were attempting to verify it, I don't know.

I work for a TPA (covered entity), and our legal office has a disagreement over whether we can disclose to the plan subscriber if an adult child is or is not enrolled on the subscriber's (the parent's) plan. I say that their enrollment information is PHI and we need approval from the adult child. Another attorney says it isn't PHI, and we can tell the parent who is enrolled on his/her plan. Please weigh in.