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Is Accidental Sharing of Personal Information Reportable?
HR Daily Advisor Link to more items from this source
Sept. 14, 2022

"[An] employee's health plan enrollment information does not become protected health information (PHI) subject to HIPAA until it is in the hands of the health insurer (or, if the plan is self-funded, the staff or service provider responsible for plan administration). The enrollment information entered on an employee portal would likely be considered an employment record (rather than PHI) ... Assuming then that HIPAA does not apply, the response to an accidental disclosure of personal information will depend on state law[.]"

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