Are you gagging?

In 2020, Congress adopted a ban on insurer and group health plan contracts containing “gag clauses” on health care price and quality information. The ban was included in the Consolidated Appropriations Act, 2021 (CAA 2021) and took effect on December 27, 2020. Group health plans and insurers must annually attest to compliance with the gag…

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Health Information Security – Credit for Trying

Last year, Congress directed the Secretary of Health and Human Services (HHS) to take into consideration efforts by organizations subject to HIPAA security standards (“covered entities” and “business associates”) to implement “recognized security practices” whenever HHS determines fines and other remedies for HIPAA security violations. …the Secretary shall consider whether the covered entity or business…

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How Much Did You Earn?

When a traditional marketplace changes and we save money, we cheer it as “disruptive innovation.” That was one of the big ideas behind the Affordable Care Act (ACA) healthcare marketplace and Exchanges like Washington’s Healthplanfinder.  Buy direct and save; avoid sales commissions. Be your own insurance broker or ask a “navigator.” But, as the Harvard…

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Most Birds may Flock Together

The Washington State Attorney General has answered a question of which types of health care professionals can “flock together” to form a multidisciplinary professional limited liability company. The answer – every profession noted in the state statute other than physical and occupational therapists who must flock amongst themselves. The question of who can own a…

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Pandemic Advice from DOL, IRS, and OIC

Government response to the Coronavirus has included a wide range of emergency measures governing health plan administration. Some of these measures address dislocations caused by sudden change in employment status while others address administration of benefits for employees marooned at home. The fast pace of change wrecks the predictability required for health care benefits tied…

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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…

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