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G-L-B’s Applicability To Health Care Organizations

G-L-B’s Applicability To Health Care Organizations. Kirk J. Nahra Wiley Rein & Fielding LLP Washington, D.C. 202.719.7335 KNahra@WRF.com Fourth National HIPAA Summit (April 26, 2002). Focus. Scope of G-L-B Differences in terms and applications

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G-L-B’s Applicability To Health Care Organizations

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  1. G-L-B’s Applicability To Health Care Organizations Kirk J. Nahra Wiley Rein & Fielding LLP Washington, D.C. 202.719.7335 KNahra@WRF.com Fourth National HIPAA Summit (April 26, 2002) Wiley Rein & Fielding LLP

  2. Focus • Scope of G-L-B • Differences in terms and applications • Intersections and overlaps with HIPAA • Who should care about G-L-B and why? Wiley Rein & Fielding LLP

  3. Who Is Covered? • Any company “significantly engaged” in financial activities • Banking • Securities • Insurance (all lines) • Odd assortment of other companies • Retailers who issues their own credit cards, real estate and personal property appraisers, tax preparers, automobile dealerships who lease automobiles, developers of financial software, career counselors providing advice for employees in the financial services industry and businesses that print and sell checks for consumers Wiley Rein & Fielding LLP

  4. Key Terms • Affiliates/non-affiliates • Disclosure/use • Opt-out/opt-in • Customers and consumers Wiley Rein & Fielding LLP

  5. NAIC Model • Separate category for health information • ERISA beneficiaries covered? • Applies to all business units • Tougher for insurance industry than rest of financial services? • Health/financial distinction • Intersections with HIPAA Wiley Rein & Fielding LLP

  6. What Information is Covered? • Financial/health • PHI • Making sense of the distinction Wiley Rein & Fielding LLP

  7. Multiple Coverage Issues For health plans • Treatment of information • Whose information • Differences among lines of coverage Wiley Rein & Fielding LLP

  8. For health care providers • Business complexity • Tie with HIPAA • Service providers Wiley Rein & Fielding LLP

  9. Contracting Differences • Contracting Audiences • Contract Options • Contract Strategies Wiley Rein & Fielding LLP

  10. Security Issues • Security under G-L-B • Security rule for HIPAA • Privacy and security connections Wiley Rein & Fielding LLP

  11. Enforcement Activity • What lessons can be learned? • Enforcement to date • What does the future hold? • Enforcement options Wiley Rein & Fielding LLP

  12. The New HIPAA Rules(?) • Timing • Contracting issues • Non-covered products • Health insurer compliance? Wiley Rein & Fielding LLP

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