HIPAA regulations require plan sponsors to distribute a reminder notice to health plan participants no less than once every three years after issuance of the Notice of Privacy Practices (“NPP”) to inform participants that the NPP is available and how to obtain a copy.
The regulations required all employer-plan sponsors to send out an NPP by November 23, 2013. Therefore, employers who have not provided an NPP to plan participants since November 23, 2013 will be required to provide a reminder notice to plan participants by November 23, 2016.
HIPAA regulations require self-insured employers, acting in their capacity as health plan sponsors, to provide an NPP to plan participants, informing them of their rights regarding how their health information may be used or disclosed and how the participant may access his or her own health information. Plan sponsors are required to provide the NPP to plan participants when they first enroll in the plan, upon request and within 60 days of any material revision to the NPP. In addition, the plan sponsor must prominently post a copy of the NPP on any web site it maintains that provides information about its benefits or customer services.
The NPP should provide a clear, user-friendly explanation of an individual’s rights with respect to his or her personal health information and the privacy practices of the health plans and health care providers. A model NPP is available at the Department of Health and Human Services website.