HIPAA and SPDs

[oriecat]

My head is swimming from all the HIPAA lately... I should know these things but I just can't think anymore...

Does the SPD for a self-insured plan need to be changed to reflect the plan amendment? Or is sending the NPP all you need to do? Can you incorporate the NPP into the SPD, instead of sending both?

Thanks!

[Guest BenefitsLawyer]

The amendment (to permit disclosures to the plan sponsor) needs to be in the plan document, so if the SPD also serves as the plan document, the amendment needs to be in there. On the other hand, if there's a separate plan document, that's where the amendment needs to go and it does not need to be in the SPD also.

The NPP may be included in the SPD, BUT you need to remember that the timing for distribution of the NPP and for the SPD may not (probably won't) match up, and that every 3 years a health plan also needs to send its participants a reminder of the existence of the NPP and how to obtain a copy.

[oriecat]

Thank you!