HIPAA - Ensure Adequate Separation 164.314(b)(2)(ii)

Overview:
The plan documents of the group health plan must be amended to incorporate provisions to require the plan sponsor to-- (ii) Ensure that the adequate separation required by § 164.504(f)(2)(iii) is supported by reasonable and appropriate security measures.

Action Items:
1) Obtain and review plan documentation. Evaluate and determine that the plan documents of the group health plan ensures adequate separation between the group health plan and the plan sponsor, including the sponsor's employees, classes of employees, or other persons who will be given access to the EPHI.

Related Documents:
1) Plan Documents

Additional Guidance:
Separation helps alleviate risk associated with EPHI regarding group health plans. Refer to previous guidance regarding resonable and appropriate security measures.