Do HIPAA's administrative simplification rules apply to self-funded mu

[Guest Multiemplawyer]

Has anyone ever looked at whether the new HIPAA administrative simplification requirements apply to self-funded multiemployer plans? It appears that they might; I was just looking for other people's thoughts.

[Guest]

I think the Administrative Simplification regs do apply to multiemployer health plans--they apply to "health plans," and there's no exception for multiemployer plans, so I'm advising my multiemployer plan clients to get ready to comply.