Guest ooota Posted June 20, 2003 Posted June 20, 2003 does anyone have any thoughts as to whether or not a local union is required to enter into a business associate contract with its health and welfare fund? thank you in advance for your thoughts.
Steve72 Posted June 20, 2003 Posted June 20, 2003 If the union is the sponsor of the health plan, it is explicitly excluded from the definition of a "business associate". The plan amendment required by HIPAA essentially takes the place of a business associate agreement.
mal Posted June 26, 2003 Posted June 26, 2003 My understanding is that the Board of Trustees is the "plan sponsor" when talking about a multiemployer fund. Our unions have been asked to sign a business associate agreement since they assist with collections, eligibility problems, etc. Absent an agreement, the union will be effectively cut off from the HW plan. The amendment to the plan document will allow the Board access to PHI, but not the union itself.
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