Customize the attached Hi-Tech template to meet your organizational needs. As this is a legal document relating to employee training, please have counsel review.
- Make sure you have a HIPAA Hi-Tech policies and procedures manual
- Make sure you follow what your procedures say you will do. How soon do you train new employees on their obligations for protecting PHI?
- What method of training do you use. We provide this for clients through ThinkHR Training. The government also has resources http://www.hhs.gov/ocr/privacy/hipaa/understanding/training/index.html
- Are you using secure email when sending PHI via the cyber pathways? We have suggested vendors and added secure options. Even with some insurance companies I see work to be done. Costs have come down tremendously in the past few years. Options are plentiful. If you have few transactions, many of these are free.
- I use www.rpost.com. Click on the Secure Email link to go to their site. IT folks like it because it can be used entirely via website. No downloading software to interact with your server. However, it's much simpler to add a plug in to Outlook or many other popular forms of mail. Sending registered is next to the regular send button, which is a good reminder every time an electronic submission is ready to be distributed. If you use rpost.com, let me help you set it up. True to form, private information is not stored. However, you can set up the system to be notified when the recipient picks up the mail and also have a copy information sent to you. They have some free options, but I typically use much more than the allocation.
Note you must also provide this within 14 days to all NEW hires - Suggestion - amend your procedures manual for new hires and update your checklist to include the Marketplace Notice with the other information.
There are several options for delivery. A general notice or you can customize notices with the information employees may need in order to enroll in a Medicare Part D prescription plan or a Medicare Advantage plan. The notice applies to ALL members insured in your plan, which includes spouses. If the prescription drug benefits in your plan do not provide at least the actuarial equivalent of Medicare's Part D coverage an employee could be penalized by paying 1% per month additional premium for every month they did not have creditable coverage prior to enrolling in Medicare's options. If they were on a non creditable group plan for 12 months prior to joining a Medicare option, that means they pay 12% more than the regular price for the coverage. PLEASE BE CAREFUL TO COMMUNICATE THIS USING A NON CREDITABLE COVERAGE NOTICE IF YOU HAVE HIGHER DEDUCTIBLE OPTIONS THAT MAY NOT BE CONSIDERED CREDITABLE.
Most employers must submit to CMS (Centers for Medicare Services) a brief annual online reporting of your health insurance plan's prescription drug coverage creditability. It gives them a database to reference when one of your employees changes to Medicare. This should be done within 60 days of the end of the plan year you are reporting and within 30 days of any change in the status of your plan's RX creditabiity. For this particular goverment purpose, your annual plan year will be considered your renewal date (unlike Plan Years for other reporting purposes). If you report a calendar year Plan Year but your renewal is not until April, you report the information within 60 days of your renewal date. THE SITE FOR REPORTING IS https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html
Note- insurance companies typically include the required notices in the plan certificates / policies that are provided to employees. They also will provide the Summary Plan Description within the certificate in most cases. However, are they sending policies to employees that include these SPDs? They most likely are sending you electronic copies for either posting or copying. The responsibility is then the employers to make sure the documents are delivered in a timely fashion. THE KEY COMPLIANCE IS SHOWING YOUR PROCEDURAL GOVERNANCE IS TO PROVIDE EACH EMPLOYEE WITH THE REQUIRED INFORMATION.
As DOL audits increase, and regulations become more burdensome. We have a variety of solutions to help.
As DOL audits increase, and regulations become more burdensome. We have a variety of solutions to help.
If you have multiple plans, you must provide copies of the SBCs for each plan offered. Is this a lot of paper? Absolutely. Can you simply provide these on an intra company website or an employee benefit website? For new hires there are some exceptions.
Corporate Insurance Advisors, Inc. does not intend to provide legal or financial advice.