HIPAA and Marketing by a Business Associate

[Guest tm3333]

Employer sends notice to an insurance agency that an employee is terminating and requests the agency notify the carrier to have the employee removed from the group plan.

1. May the insurance agency mail the former employee a brochure/business card to provide information about individual coverage options?

2. May the former employer mail the former employee the insurance agency's brochure/business cards?

3. If an employer is sending a COBRA notice to a former employee, may the employer also include the insurance agency's brochure/business cards to provide the former employee with alternatives to COBRA?