Tougher Privacy Standards for Exchanges

TEASER: “We considered but declined to use the definitions for these terms provided under the HIPAA regulations because the protected health information (PHI) that triggers the HIPAA requirements is considered a subset of PII [Personally Identifiable Information], and we believe that the HIPAA definitions would not provide broad enough protections to satisfy the requirements under…

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Association Plan Redux – Bona Fide Grandfathers

Six months before the health reform cuckoo clock strikes, the Washington Office of the Insurance Commissioner (OIC) has changed agency policy which required associations to prove its ERISA “bona fide” status and which rejected grandfather status for employers insured through associations. I say to those bitter folks clinging to their guns and their religion, better…

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