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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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…

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New Washington Rules for almost bona fide AHPs

The Washington Insurance Commissioner (OIC) adopted emergency rules governing association health plans (AHPs) created under the recently liberalized Department of Labor (DOL) standards for bona fide AHPs. The liberalized standards allow loosely affiliated small businesses to become eligible for treatment as a large group plan under ERISA. Under the DOL regulations which took effect for…

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DOL Creates Two Kinds of AHPs – “Old School” and “New Age”

The U.S. Department of Labor (DOL) issued final regulations liberalizing standards for association health plans (AHPs) that DOL will recognize as single, large group health plans. The final regulations permit a more tenuous connection among participating employers and allow sole proprietors without employees to be considered employers. But the biggest change is the creation of…

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