Guest budman Posted January 29, 2003 Posted January 29, 2003 A health plan must provide a Notice of Privacy Practices to all employees. Is the TPA also required to provide the TPA's privacy notice to the employees so essentially the employees are receiving 2 notices?
Jbentz Posted January 30, 2003 Posted January 30, 2003 Why would a TPA be sending an NPP? Most TPAs are not Covered Entities, only Business Associates of a plan, so they are not required to send one. They may be contracted to provide this service FOR their clients, and i suppose that they could send their own, but i don't know why they would want to. If they are handling this for you, I believe one will suffice.
Guest kowen Posted January 30, 2003 Posted January 30, 2003 The health plan is the covered entity and must provide the privacy notice. If the health plan is insured and the insurer doesn't disclose PHI to the employer, the insurer will issue the notice, and undertake most of the Privacy compliance activities. A TPA providing administrative services to a self insured health plan, in most cases, will be a business associate and does not have to issue the notice. If your TPA is an insurance company, you may be able to negotiate with them to provide Privacy related services.
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