rocknrolls2 Posted April 6, 2020 Posted April 6, 2020 I was drafting a Coronavirus-related distribution application form, which included the certification that the applicant is an eligible individual. The question I have is since the employee has to represent that s/he has been diagnosed with Coronavirus, that a spouse or dependent child has or that s/he has experienced adverse financial consequences, the first two trad awfully close to HIPAA protected health information. Fortunately, this client has a TPA that will be administering this provision (as well as other facets of the plan). The question that I have is does the possible application of the first two grounds of qualifying for a coronavirus-related distribution subject the plan to all the HIPAA privacy requirements? I would like to hear your thoughts on this.
MoJo Posted April 6, 2020 Posted April 6, 2020 Why are you asking if they have been diagnosed? Our forms says (and I'm paraphrasing here): A "qualified individual" is defined as: 1) diagnose, spouse dependent; 2) suffered an adverse financial consequence as a result of ...." and then the verification: "I certify that I meet one or more of the criteria to be considered a "qualified individual" as described above." Get their signature, a date and move on. I don't *want* to know why they qualify, and the Act allows reliance on the self certification. Period. Mike Preston, Bill Presson and hr for me 3
Mike Preston Posted April 7, 2020 Posted April 7, 2020 3 hours ago, MoJo said: Get their signature, a date and move on. I don't *want* to know why they qualify, and the Act allows reliance on the self certification. Period. Can I get an "Amen"!!!??? hr for me and Bill Presson 2
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