Bates & Company, Inc.
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Loan & Distribution Specialist AimPoint Pension
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AimPoint Pension
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Regional Vice President of Sales The Retirement Plan Company
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Compass
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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The Anthem Data Breach: Overview of HIPAA and Other Consequences (PDF)
Lockton Feb. 7, 2015 "Where Anthem is acting as an insurer, and the employer is not 'hands on' with the plan's PHI (i.e., it does not acquire, maintain, or transmit the plan's PHI), the notice and disclosure obligation is Anthem's.... Where the health plan is self-insured and Anthem is acting as a 'business associate' of the plan, Anthem (as the plan's third-party claims payor) has a duty under HIPAA/HITECH to notify the employer health plan of the breach. Generally, it is the health plan's responsibility to then supply notice to affected individuals and, in some cases, federal authorities and media outlets. However, health plans and their business associates may agree upon who will actually supply the notice.... Anthem has pledged to supply notice to all affected individuals." |
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