John S. Conniff is an attorney admitted to practice in Washington and Oregon. He attended Seattle University undergraduate and earned his law degree from Seattle University. He served as counsel to the Washington State Legislature, was Deputy Insurance Commissioner for Health care and now practices law in his own firm concentrating on health, insurance, and business matters.

New HIPAA Risk Assessment Tool

The Office of the National Coordinator for Health Information Technology (ONC), in collaboration with the HHS Office for Civil Rights (OCR) just posted an updated Windows only version of its HIPAA risk assessment tool (SRA). I know; lots of exciting acronyms, abbreviations, and labels! You can download the new software on the government’s Health IT…


Washington Revises Bona Fide Association Filing Standards

The Washington Insurance Commissioner (OIC) has proposed new rules to codify current procedures for filing large group health plans for bona fide associations. Under current requirements, the agency provides instructions for filing association health plans qualifying as a single large group plan under ERISA rather than rules governing these filings. The OIC requires that insurance…


Judge Unimpressed with AHP Magic Trick

On Thursday, a federal court judge for the District of Columbia struck down the new Department of Labor’s (DOL) association health plan (AHP) rules declaring, “these provisions are unlawful and must be set aside…[and the] bona fide association and working owner provisions are therefore vacated.” As an attorney, I cringe thinking about fellow attorneys standing…