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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