Blue Cross and Blue Shield of Illinois

 

August 16, 2013

Legislative Update
Status of HIPAA Omnibus Rule Implementation for ASO Customers

Blue Cross and Blue Shield of Illinois (BCBSIL) is in the process of implementing the Health Insurance Portability and Accountability Act (HIPAA) Omnibus Rule that the federal government finalized on Jan. 17, 2013. The following is an update on how the Omnibus Rule impacts our ASO customers.

Business Associate Agreements/Addendums 

  • Existing ASO customers on a standard BCBSIL template:
    We reviewed our current Business Associate Agreements/Addendums (BAAs) and have concluded that the content of the BAA complies with the spirit of the Omnibus Rule. Therefore, we will not actively amend existing BAAs. However, if an employer group’s legal counsel believes that changes need to be made to the current BAA due to the Omnibus Rule, please forward these changes to your account representative.
  • Existing ASO customers on a customized non-standard BCBSIL template:
    We will not actively amend these BAAs. However, if an employer group’s legal counsel believes that changes are required in order to comply with the Omnibus Rule, please forward these changes to your account representative.
  • New ASO customers:
    The current BCBSIL template BAAs will be available through your account representative when they are finalized. 

Individuals’ Right to Access Their Protected Health Information
BCBSIL has amended its policies and procedures to allow individuals who request a copy of their Protected Health Information (PHI) to receive it in an electronic format.

Standard for Data Breaches
For groups who have delegated Health Information Technology for Economic and Clinical Health (HITECH) Act breach notification services to BCBSIL, we will be using the new objective, four-factor risk assessment test to comply with the requirements under the Omnibus Rule.

 
 
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A Division of Health Care Service Corporation, a Mutual Legal Reserve Company,
an Independent Licensee of the Blue Cross and Blue Shield Association.