In January 2013, HHS issued significant new HIPAA regulations. The primary purpose of the regulations is to implement the HITECH amendment to HIPAA. In addition, HHS released new sample business associate agreement provisions. Employers need to update their prior HIPAA compliance efforts in response to the new regulations.
Miller Johnson has prepared a compliance kit to assist employers in their capacity as health plan sponsors to update their HIPAA privacy and security procedures and documents for HITECH and the new final regulations. The kit includes a hard copy and electronic versions of the following:
- Compliance instructions
- Updated HIPAA policies and procedures incorporating the final regulations, including the new breach notification procedures
- Sample notice to individuals in the event of a breach of unsecured protected health information (“PHI”)
- Revised participant notice of privacy practices
- New business associate agreement. Included with the business associate agreement is a cover letter to the business associate describing the changes which have been made in order to comply with the final regulations and providing the rationale why your version of the business associate agreement should be used rather than any version supplied by the business associate
- Two sample Power Point training documents. The first is to provide training to existing employees in the group with access to PHI regarding the final regulations and to provide refresher training regarding the HIPAA privacy and security rules. The second is to provide initial HIPAA training (for example, to a new hire or employee transferred into the group with access to PHI)
- Annual checklist to facilitate ongoing compliance
Miller Johnson is offering employers a new compliance kit to address the final regulations and all of the employer’s HIPAA / HITECH compliance requirements. If you are an employer that previously purchased a compliance kit from Miller Johnson, the cost of the new kit is $500. It is intended to replace the prior kit. If you are an employer that has not previously ordered a compliance kit from Miller Johnson, we are also making the kit available to you. Your cost of the kit is $850. However, please note that we are providing a $100 discount to employers (new and returning customers) who attend one of our HIPAA / HITECH workshops.
The kit is intended for use by employers in their capacity as health plan sponsors. It is for the purpose of addressing all of the documents needed in order to comply with the final regulations. As a result, it should update and replace prior HIPAA and HITECH compliance efforts.
If you are a business associate (including a subcontractor), the final regulations require you to directly comply with HIPAA in a manner similar to employer health plans. Miller Johnson also offers a compliance kit specifically designed for business associates. It updates and replaces the prior kit for business associates offered by Miller Johnson. If you are a returning customer, we are making the kit available to you for $400. If you are a business associate that previously has not ordered a kit from Miller Johnson, the cost of the kit is $600. Again, we provide a $100 discount off of these prices to business associates who attend one of our HIPAA / HITECH workshops.
If you have any other questions about HIPAA or HITECH, please contact any member of the Employee Benefits Practice Group.