| 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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