HIPAA Privacy and OHCA

[alexa]

We are a small health plan sponsor attemptign to comply with HIPAA Privacy by 4/14/2004.

How many are utilzing the OHCA ?

We have 1 health plan anyway since all are covered under a wrap document (i.e. medical, dental, vision, health FSA, and EAP)

For those forming an OHCA with the plan's carriers, have the carriers agreed in writing to this?

any insight on the value of an OHCA?

we have self-insured medical and vision plans so must comply with all of HIPAA Privacy requirements anyway

[Steve72]

For what purpose are you considering an OHCA? If you are self funded, there is no need (and no possibility) of forming an OHCA with carriers, as TPAs are not covered entities.

Do you mean consolidating all of your health "plans" into an OHCA? This is certainly possible, and permits you to issue a single Privacy Notice.

There does not appear to be any requirement that an OHCA be formalized or documented in any way.

[alexa]

I guess I meant with our fully insured plan carriers, dental , our 2 HMO's , our self insured medicla and vision plan carriers

All of our plans fall in 1 health plan document so wasn't speaking of health plan itself, just carriers

It is my understandign the fully-insured carriers take the stance that they are CE's?

[Steve72]

Fully insured carriers ARE CEs, there's no question about that.

I seriously doubt you'll be able to convince all of your carriers to act as an OHCA. Each carrier will issue its own separate privacy notice.