PHI

[Guest ybahti]

Is a benefits summary that lists an employee's medical coverage, premiums, effective date and covered dependents considered PHI?

[Steve72]

Enrollment information, if held by the plan, is considered PHI.

[Sandra Pearce]

I believe from an employer's standpoint the same information, such as a group billing with employee name, effective date, type coverage, monthly premium, is not considered Protected Health Information.

[Steve72]

That's right. A plan can release enrollment information to the employer. Once held by the employer in its role as employer, the information is not PHI.

However, the source of the information should be documented (e.g., request goes to HR, not benefits) to ensure no difficulties arise due to the dual nature of this information.

[Guest ybahti]

Makes sense. Now what if the employer is self insured such that they ARE the plan..?

[Steve72]

"Makes sense. Now what if the employer is self insured such that they ARE the plan..? "

The employer is never the plan.

There are still considered to be two separate entities. Individuals who have access to PHI in their role in acting for the plan must be trained not to use PHI for the employer, or release PHI to individuals who do not have a legitimate plan purpose for accessing the PHI.

As discussed below (edited: as discussed ABOVE), enrollment information may be released from the plan to the employer for the employer's use. Once held by the employer, the information is no longer PHI.