The American Bar Association’s Joint Committee on Employee Benefits has posted its report of its annual question and answer session with representatives from HHS’s Office for Civil Rights (OCR).
The following are some excerpts from the Q&A session between the Department of Health and Human Services and the Joint Committee on Employee Benefits. For those employers or Third Party Administrators (TPAs) offering participants health risk assessments (HRAs) or electronic personal health records (PHRs) you should be aware of the opinions of the OCR on whether certain scenarios would violate the HIPAA Privacy rules.
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