Health & Welfare Plans: First Quarter Reminders
The helter-skelter of the holiday season is over & Spring is just around the corner! In the world of health & welfare benefits, let’s remember […]
A Stitch in Time Could have Saved…$1.6 Million in HIPAA Penalties?
If you’re a Covered Entity (“CE”), that “creates, receives, maintains, or transmits electronic Protected Health Information (“ePHI”)”, then perhaps the recent string of HIPAA violations […]
Did Procrastination Play a Part in HIPAA Privacy Breach?
We often see headlines about breaches of the HIPAA Security Rule, commonly for failures to adequately either (1) conduct & implement a Security Risk Assessment; […]
Open Enrollment, Oh My!
Open Enrollment (“OE”) season, for many HR professionals, may create symptoms of anxiety: sweaty palms, racing hearts, and sleepless nights (not to mention consumption of […]
What is a “Functional” Fiduciary?
ERISA’s Fiduciary Duties Understanding the nature of an ERISA benefit-plan-fiduciary is a big deal; naming fiduciaries and identifying “fiduciary-like” decisions is an even bigger one. […]
Who, What, and Now What? Business Associate HIPAA Obligations
It’s likely you’ve seen post after post discussing the Office for Civil Right’s (“OCR”) recent guidance for Business Associates (“BA”) listing scenarios when BA may […]
IRS Revises EPCRS Guidance, Expands Corrections Available Under Self-Correction Program
On April 19, 2019, the Internal Revenue Service (“IRS”) issued Revenue Procedure (“Rev. Proc.”) 2019-19 –the most recent comprehensive official guidance to the IRS’s Employee […]
HHS lowers HIPAA annual upper limits to better reflect text of HITECH Act
The Department of Health & Human Services (“HHS”) has issued a Notification of Enforcement Discretion for the Health Information Technology for Economic and Clinical Health […]
2020 Medicare Part D Benefit Parameters Released
Click here to access the full Announcement from CMS on April 1, 2019. Click here to access 2020 Medicare Advantage Ratebook details via CMS’ website. […]