Jump to content

Recommended Posts

Posted

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.

Posted

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.

Posted
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"!!!???

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
×
×
  • Create New...

Important Information

Terms of Use