Employers sponsoring health plans (particularly self-insured plans), and other covered entities and their Business Associates, should be aware of the March 1, 2023 deadline to report certain breaches that may have occurred in 2022 under the Health Insurance Portability and Accountability Act (“HIPAA”).
Aside from this reporting requirement, it may be a good time during the early part of 2023 to have ERISA counsel provide HIPAA training and review all HIPAA policies and procedures.