As many employers know, HIPAA rules require them to sign on behalf of their health plans Business Associate Agreements (BAAs) with the vendors who assist in plan administration. Many employers also know that earlier this year, the U.S. Department of Health and Human Services issued final regulations which will require updated BAAs by September 23, 2013 or September 23, 2014, depending on the circumstances. Among the plans covered by these rules are medical flexible spending accounts, other than plans that are self-administered and have fewer than 50 participants.
My colleague Blake Schofield recently published an Insight article for clients of our firm regarding the new requirements for BAAs. Employers needing to update their BAAs may find it of interest.
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