Summary of Group Health Plan Regulations

IF the health plan is... Then the plan sponsor/employer must AND Wellmark
  • Fully insured and 
  • Receives Personal Health Information (PHI)
  • Provide certification of privacy regulation compliance to Wellmark 
  • Provide notice of privacy policy upon request of the plan
  • Send our Privacy Notice to all plan participants.
  • Provide sample documents as appropriate at the direction of the plan sponsor.  The provision of sample documents is not intended to constitute legal advice.
  • Fully insured and 
  • Does not receive PHI (except for enrollment and summary information).  Summary health information summarizes claim history, claim expenses or types of claim experience and is "de-identified" except for limited geographic information.
  • Use the summary health information only for the purposes allowed by the HIPAA-AS privacy rule
  • In this case, the plan sponsor has no obligations under the federal regulation to protect PHI.
  • Send our Privacy Notice to all plan participants.
  • Provide sample documents as appropriate at the direction of the plan sponsor.  The provision of sample documents is not intended to constitute legal advice.
  • Partially self funded and 
  • Receives PHI and 
  • Wellmark provides partial group health plan coverage
  • Send its Privacy Notice to all plan participants. 
  • Amend its plan document to include privacy provisions.
  • Provide certification of privacy regulation compliance to Wellmark.
  • Send our Privacy Notice to all plan participants.
  • Amend agreement with plan sponsor to comply with Business Associate contract requirements.

  • Partially self funded and 
  • Receives PHI and 
  • Wellmark does not provide partial group health plan coverage

  • Send its Privacy Notice to all plan participants. 
  • Amend its plan document to include privacy provisions.
  • Provide certification of privacy regulation compliance to Wellmark.

  • Amend agreement with plan sponsor to comply with Business Associate contract requirements.
  • Provide sample documents as appropriate at the direction of the plan sponsor.  The provision of sample documents is not intended to constitute legal advice. 

  • Fully self funded and 
  • Receives PHI
  • Send its Privacy Notice to all plan participants. 
  • Amend its plan document to include privacy provisions.
  • Provide certification of privacy regulation compliance to Wellmark.

  • Amend agreement with plan sponsor to comply with Business Associate contract requirements.
  • Provide sample documents as appropriate at the direction of the plan sponsor.  The provision of sample documents is not intended to constitute legal advice. 
 
 
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Wellmark Blue Cross and Blue Shield is an Independent Licensee of the Blue Cross and Blue Shield Association doing business in Iowa and South Dakota.
 
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