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HIPAA Security and Privacy Policies and Procedures Overview <br />[HIPAA Security and Privacy] <br />Policy Statement <br />HIPAA requires covered entities to have policies and procedures reflecting HIPAA's privacy and security <br />mandates. The Health Plan, as a covered entity, has developed administrative policies and procedures <br />reflecting the Health Insurance Portability and Accountability Act of 1996 (HIPAA) privacy and security <br />regulations. <br />Policy Interpretation and Implementation <br />HIPAA Policies and Procedures <br />Health Plan <br />Organized Health Care <br />Arrangement (OHCA) <br />Work Together <br />1. HIPAA requires covered entities to have policies and <br />procedures to ensure compliance with HIPAA's <br />regulations. A health plan is a "covered entity" under <br />HIPAA. Consequently, the Health Plan is responsible for <br />the research, development, implementation, monitoring <br />and maintenance of the Health Plan's HIPAA privacy and <br />security policies and procedures regarding protected <br />health information (PHI) and electronic protected health <br />information (ePHI). <br />2. HIPAA defines a "health plan" as an individual or group <br />health plan that provides or pays the cost of medical care, <br />including, but not limited to, employee welfare benefit <br />plans covered by ERISA, health insurers, HMOs, group <br />health plans, and many public benefit programs <br />(Medicaid, Medicare, etc.). <br />3. HIPAA recognizes Organized Health Care Arrangements <br />(OHCAs). An OHCA can exist when an employer sponsors <br />more than one health plan that is a covered entity. Being <br />part of an OHCA allows the covered entities to satisfy the <br />HIPAA privacy and security requirements together, as if <br />they are a single covered entity. The following covered <br />entities are designated as an OHCA: <br />Blue Cross and Blue Shield / HRA <br />For purposes of these HIPAA policies and procedures, "Health <br />Plan" means the OHCA designated above. <br />4. The policies and procedures prepared for purposes of <br />HIPAA Privacy compliance and the policies and procedures <br />prepared for purposes of HIPAA Security compliance are <br />intended to work together. <br />City of Ramsey HIPAA Security Policy - 2 - <br />