HIPPA SPD Disclosure

[Guest justbe]

Should health care providers include a HIPPA privacy statement in their summary plan descriptions? Is it required by law? If so, what is the cite. Thank you

[Steve72]

By "health care providers" I assume you mean sponsors of health plans ("Health care providers" is a defined term under HIPAA which includes doctors, hospitals, etc.)

HIPAA contains a specific requirement for a notice of privacy practices (NOPP). This is a separate requirement from the SPD.

Because the disclosure requirements are not identical, I generally advise that the NOPP be provided separately from the SPD.

Note that some have taken the position that the HIPAA amendment requires a summary of material modifications, in addition to the NOPP. I do not believe this is correct.