HIPAA Privacy Rules and Compliance for Self-Funded Plans and Third-Party Administrators

BARBRI

This CLE webinar will provide plan sponsors and counsel an in-depth analysis of HIPAA privacy rules and regulations for self-funded plans and third-party administrators. The panel will discuss the requirements for regulated entities and under what circumstances they are prohibited from disclosing healthcare information.

Description

Health plans and administrators must balance the privacy concerns of patients with the need to protect patients. Covered entities and business associates under HIPAA must consider HIPAA and other privacy law obligations in light of increased focus on self-funded plans.

HIPAA-covered entities include self-funded employee benefit plans and may administer the plans themselves or engage a third-party administrator. Applying HIPAA rules to these entities is complex and may vary depending on how the plan is structured.

On Apr. 23, 2026, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced HIPAA privacy and security enforcement actions against a self-funded employee benefit plans. The initiative emphasizes their position that self-funded plans, and not just their third-party administrators, are directly accountable for HIPAA compliance, with limited exceptions. These exceptions are often narrow, and counsel must understand when an exception applies and when it does not. This can cause various compliance issues for self-funded plans and administrators attempting to limit liability and avoid compliance mishaps when handling data, group policies, and access to information.

To comply with health privacy laws while meeting the disclosure needs for public health purposes, plan sponsors and their counsel should have policies and procedures in place to ensure the strict requirements for disclosure are met.

Listen as our panel examines HIPAA and other privacy laws as applied to self-funded plans and third-party administrators.

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