When was the last time you made certain all of the beneficiary statements you have created are still appropriate?
If you are like many people that I help, the answer is, “I am not sure I have ever reviewed the beneficiaries I assigned years ago.”
In a recent article in Investment News, about 80% of beneficiary forms on individual retirement accounts, defined benefit pension plans and insurance policies are either blank, outdated or not properly filled in.* We want our clients to be the other 20%.
Without a comprehensive beneficiary review, you may be leaving assets to those you did not intend or no one at all. A comprehensive review of your beneficiaries can ensure that your assets go to exactly whom you wish.
Before you launch into this project, you need to determine all of the different places you might have a beneficiary contract in place. Of course, the primary document is your Will, but many individuals use a Living Trust as the primary instruction document instead of a Will.
In addition to your will, you will also need to review:
• IRA, 401(k), 403(b) or other similar accounts
• Annuity, life insurance, and long term care policies
• Brokerage accounts
• Existing bank accounts, to include Certificates of Deposit
Structuring your legacy is one of the most important pieces of the retirement process but often times, it is an overlooked portion of the process as it produces no income for a financial advisor. We always strive to add real value to our clients and fully realize that relationships are built over time, not transactions.
We have cleared our schedules during the month of BLANK to offer Complimentary Beneficiary Reviews. We want to spend an hour making sure your beneficiaries are EXACTLY the way you want them to be.
During your consultation, you’ll receive your personal Legacy Planning Kit, which includes:
• A Beneficiary Review and Update Assistance
• A copy of our step-by-step manual: “A Guide to Your IRA Beneficiary Choices”
• Complimentary copy of “Understanding Trusts” and “Advantages of a Will’
You will also walk away with a completed From the Heart Journal that encompasses:
• Account numbers, policy numbers and company names of all investments and real estate
• Location, phone numbers, and contacts for wills, trusts, bank accounts, and credit cards
• Names and contacts of Bankers, Attorneys, Accountants, etc
• Funeral instructions
Call us at 888.991-2929 to schedule you complimentary Beneficiary Review. We will save a copy of our Legacy Planning Kit and From the Heart Journal just for you.
Sincerely,
Grant Davis
GDI Insurance Agency, Inc
888-991-2929
www.gdiinsurance.com
Complimentary Beneficiary Review, Grant Davis GDI
When was the last time you made certain all of the beneficiary statements you have created are still appropriate?
If you are like many people that I help, the answer is, "I am not sure I have ever reviewed the beneficiaries I assigned years ago."
In a recent article in Investment News, about 80% of beneficiary forms on individual retirement accounts, defined benefit pension plans and insurance policies are either blank, outdated or not properly filled in.* We want our clients to be the other 20%.
Without a comprehensive beneficiary review, you may be leaving assets to those you did not intend or no one at all. A comprehensive review of your beneficiaries can ensure that your assets go to exactly whom you wish.
Before you launch into this project, you need to determine all of the different places you might have a beneficiary contract in place. Of course, the primary document is your Will, but many individuals use a Living Trust as the primary instruction document instead of a Will.
In addition to your will, you will also need to review:
- IRA, 401(k), 403(b) or other similar accounts
- Annuity, life insurance, and long term care policies
- Brokerage accounts
- Existing bank accounts, to include Certificates of Deposit
Structuring your legacy is one of the most important pieces of the retirement process but often times, it is an overlooked portion of the process as it produces no income for a financial advisor. We always strive to add real value to our clients and fully realize that relationships are built over time, not transactions.
We have cleared our schedules during the month of BLANK to offer Complimentary Beneficiary Reviews. We want to spend an hour making sure your beneficiaries are EXACTLY the way you want them to be.
During your consultation, you'll receive your personal Legacy Planning Kit, which includes:
- A Beneficiary Review and Update Assistance
- A copy of our step-by-step manual: "A Guide to Your IRA Beneficiary Choices"
- Complimentary copy of "Understanding Trusts" and "Advantages of a Will'
You will also walk away with a completed From the Heart Journal that encompasses:
- Account numbers, policy numbers and company names of all investments and real estate
- Location, phone numbers, and contacts for wills, trusts, bank accounts, and credit cards
- Names and contacts of Bankers, Attorneys, Accountants, etc
- Funeral instructions
Call us at 888.991-2929 to schedule you complimentary Beneficiary Review. We will save a copy of our Legacy Planning Kit and From the Heart Journal just for you.
Sincerely,
Grant Davis
GDI Insurance Agency, Inc
888-991-2929
Business Planning, Systems. Easy to understand truth, brings peace
It seems the past few years as the economy has turned I have spent a lot of time working more as a business consultant with many of my clients than an insurance broker. My core business belief is that my job is to help my clients in whatever way I can. Insurance is somewhat complicated, but we have systematized everything so well that we can easily get good coverage terms, and the best rates.
One thing about using systems well is it is a bit boring, and very easy to accomplish the few things an insurance agency needs to do… Get the lowest rates, for the right coverage. In about a week I can train a person right out of high school which buttons to push on the key board to do this.
So I find myself doing more for our clients, in fact it is the very system I developed to run GDI that I end up sharing with most of my clients to help them run their businesses. It seems the concepts are adaptable to other kinds of products and services.
I know that sounds like a very simple truth. But then again all positive change starts with understanding a simple truth. Keep in mind that truth is much different than correct. Being correct doesn’t always mean you are working with truth! In the attached picture I took this morning of one of my trees, the tree is correctly growing and looks healthy. The truth is as you look closer there are some bare spots, and some dead wood, there are on this one tree some branches that are producing a lot more nuts than other branches. So the truth is this tree can be improved.
The second thing I always do is once I have found the truth, I need to be able to present it, and explain it in a manner that can be easily understood, and accepted by whoever I am working on. So the details of how this tree can be improved, and what that improvement will mean to the owner of the tree in terms of production, or cost savings is vital. But you see how first understanding the truth is vital.
What do I sell then? Peace! I sell peace! The peace that comes from understanding the truth of a situation, developing a plan that is easy to understand and implement to correct a bad situation, or improve a good situation, etc… My goal then is to simply help my clients with whatever they need help with.
Sometimes it is getting a lower premium. Other times it is getting the proper coverage. Sometimes it is helping them with their marketing, or sales systems, or budgets, or taxes, etc… If it is in me it is available to my clients.
Many of use are in a service business. I think as we consider what service we are offering, all comes down to helping someone, or a business solve a problem, and improve the quality of life and or business.
One thing about using systems well is it is a bit boring, and very easy to accomplish the few things an insurance agency needs to do… Get the lowest rates, for the right coverage. In about a week I can train a person right out of high school which buttons to push on the key board to do this.
So I find myself doing more for our clients, in fact it is the very system I developed to run GDI that I end up sharing with most of my clients to help them run their businesses. It seems the concepts are adaptable to other kinds of products and services.
Lately most businesses I work with need more sales. They have already cut back, and done the things they needed to do to save money. Now they need to start to grow again. The last few weeks I have been thinking a lot about this, and last night walking in my almond orchard looking at the new nuts starting to show on various trees I was thinking that not every tree in the orchard is the same. I considered that my orchard had many trees, and even sections of my orchard
The second thing I always do is once I have found the truth, I need to be able to present it, and explain it in a manner that can be easily understood, and accepted by whoever I am working on. So the details of how this tree can be improved, and what that improvement will mean to the owner of the tree in terms of production, or cost savings is vital. But you see how first understanding the truth is vital.
What do I sell then? Peace! I sell peace! The peace that comes from understanding the truth of a situation, developing a plan that is easy to understand and implement to correct a bad situation, or improve a good situation, etc… My goal then is to simply help my clients with whatever they need help with.
Sometimes it is getting a lower premium. Other times it is getting the proper coverage. Sometimes it is helping them with their marketing, or sales systems, or budgets, or taxes, etc… If it is in me it is available to my clients.
Many of use are in a service business. I think as we consider what service we are offering, all comes down to helping someone, or a business solve a problem, and improve the quality of life and or business.
Health Care Reform Timeline, Grant Davis GDI
On March 23, 2010, President Obama signed into law the health care reform bill, the Patient Protection and Affordable Care Act. This legislation, along with the Health Care and Education Reconciliation Act of 2010, makes sweeping changes to the U.S. health care system. These changes will be implemented over the next several years.
This Legislative Brief provides a timeline of the implementation of key reform provisions that affect employers and individuals. Please read below for more information and contact Grant Davis GDI, with any questions about how you can prepare for health care reform.
2010
Expanded Insurance Coverage
The health care reform law contains some provisions designed to provide immediate improvements in access to health care coverage.
• Extended Coverage for Young Adults. Group health plans and health insurance issuers offering group or individual health insurance coverage that provides dependent coverage of children must make coverage available for adult children up to age 26. There is no requirement to cover the child of a dependent child. This requirement will apply to grandfathered and new plans.
Note: a “grandfathered plan” is one in which an individual was enrolled on March 23, 2010, and to which there is no change to existing coverage. Many requirements of the new law do not apply to grandfathered plans and nothing in the law requires individuals terminate coverage in which they were enrolled when the law was passed. A plan can still be a grandfathered plan even if family members or new employees are allowed to join.
• Access to Insurance for Uninsured Individuals with Pre-Existing Conditions. The health care reform bill provides for the establishment of a temporary high risk health insurance pool program to provide health insurance coverage for certain uninsured individuals with pre-existing conditions. The program will end when the health insurance exchanges, set to be established in 2014, are operational.
• Identifying Affordable Coverage. The Secretary of Health and Human Services is required to establish an Internet website through which residents of any state may identify affordable health insurance coverage options in that state. The website will also include information for small businesses about available coverage options, reinsurance for early retirees, small business tax credits, and other information of interest to small businesses. So-called “mini-med” or limited-benefit plans will be precluded from listing their policies on this website.
• Reinsurance for Covering Early Retirees. The new law requires the establishment of a temporary reinsurance program to provide reimbursement to participating employment-based plans for a portion of the cost of providing health insurance coverage to early retirees and their spouses, surviving spouses and dependents. This program will end on January 1, 2014.
Health Insurance Reform
The new law also imposes requirements on health insurance issuers to reform certain insurance practices and improve the coverage available.
• Eliminating Pre-Existing Condition Exclusions for Children. Group health plans and health insurance issuers may not impose pre-existing condition exclusions on coverage for children. This provision will apply to all employer plans and new plans in the individual market. This provision will also apply to adults in 2014.
• Coverage of Preventive Health Services. Group health plans and health insurance issuers offering group or individual health insurance coverage must provide coverage for preventive services. These plans also may not impose cost sharing requirements for preventive services.
• Prohibiting Rescissions. The health care reform law is designed to prohibit abusive rescissions of coverage by insurance companies when an individual gets sick as a way of avoiding covering the cost of the individual’s health care needs. Group health plans and health insurance issuers offering group or individual insurance coverage may not rescind coverage once the enrollee is covered, except in cases of fraud or intentional misrepresentation. Plan coverage may not be cancelled without prior notice to the enrollee. This provision applies to all new and existing plans.
• Limits on Lifetime and Annual Limits. In general, group health plans and health insurance issuers offering group or individual health insurance coverage may not establish lifetime limits on the dollar value of benefits for any participant or beneficiary or impose unreasonable annual limits on the dollar value of benefits for any participant or beneficiary. This requirement applies to all plans. Annual limits will also be prohibited beginning in 2014.
Health Plan Administration
In addition to any administrative changes required by the coverage improvements described above, health plans will be subject to increased administrative duties under health care reform.
• Improved Appeals Process. Group health plans and health insurance issuers offering group or individual health insurance coverage must implement an effective appeals process for appeals of coverage determinations and claims. At a minimum, plans and issuers must:
o have an internal claims process in effect;
o provide notice to enrollees, in a culturally and linguistically appropriate manner, of available internal and external appeals processes, and the availability of any applicable office of health insurance consumer assistance or ombudsman to assist them with the appeals processes; and
o allow enrollees to review their files, to present evidence and testimony as part of the appeals process, and to receive continued coverage pending the outcome of the appeals process.
The internal claims process must initially incorporate the current claims procedure regulations issued by the Department of Labor in 2001. Plans and issuers must also implement an external review process that meets applicable state requirements and guidance that is to be issued.
• Nondiscrimination Rules for Fully-Insured Plans. Fully-insured group health plans will now have to satisfy nondiscrimination rules regarding eligibility to participate in the plan and eligibility for benefits. These rules prohibit discrimination in favor of highly compensated individuals. This section does not appear to apply to grandfathered plans.
Medicare/Medicaid
The health care reform law will further affect individuals by making certain changes to Medicare and Medicaid.
• Rebates for the Medicare Part D “Donut Hole.” Currently, there is a gap in Medicare prescription drug coverage. The coverage gap falls between $2,830 and $6,440 in total drug spending. The health care reform bill provides a $250 rebate check for all Medicare Part D enrollees who enter the “donut hole.” Beginning in 2011, a 50 percent discount on brand-name drugs will be instituted and generic drug coverage will be provided in the donut hole. The donut hole gap will be filled by 2020.
• Medicaid Flexibility for States. States are given a new option under the health care reform law to cover additional individuals under Medicare. States will be able to cover parents and childless adults up to 133 percent of the Federal Poverty Level (FPL).
Fees and Taxes
With a total estimated cost of over $900 billion dollars, the reform of the nation’s health care system comes with additional costs and fees. These fees will also be implemented over the next several years. However, health care reform also includes some subsidies, in the form of tax credits, to help individuals and businesses pay for coverage.
• Small Business Tax Credit. The first phase of the small business tax credit for qualified small employers begins in 2010. These employers can receive a credit for contributions to purchase health insurance for employees. The credit is up to 35 percent of the employer’s contribution to provide health insurance for employees. There is also up to a 25 percent credit for small nonprofit organizations. When health insurance exchanges are operational, tax credits will increase, up to 50 percent of premiums.
• Indoor Tanning Services Tax. One additional tax imposed by the health care reform law is a 10 percent tax on amounts paid for indoor sun tanning services.
2011
Expanded Insurance Coverage
• Voluntary Long-Term Care Insurance Options. The health care reform law creates a long-term care insurance program for adults who become disabled. Participation will be voluntary and the program is to be funded by voluntary payroll deductions to provide benefits to adults who become disabled.
Health Plan Administration
• Improving Medical Loss Ratios. Health insurance issuers offering group or individual health insurance coverage (including grandfathered health plans) must annually report on the share of premium dollars spent on health care and provide consumer rebates for excessive medical loss ratios.
• Reporting Health Coverage Costs on Form W-2. Beginning in 2011, employers will be required to disclose the value of the health coverage provided by the employer to each employee on the employee’s annual Form W-2.
• Standardizing the Definition of Qualified Medical Expenses. The health care reform law conforms to the definition of “qualified medical expenses” for HSAs, FSAs and HRAs to the definition used for the itemized tax deduction. An exception to this rule is included so that amounts paid for over-the-counter medicine with a prescription still qualify as medical expenses. Costs for over-the-counter medications obtained without a prescription would not qualify.
• Cafeteria Plan Changes. The new law creates a Simple Cafeteria Plan to provide a vehicle through which small businesses can provide tax‐free benefits to their employees. This plan is designed to ease the small employer’s administrative burden of sponsoring a cafeteria plan. The provision also exempts employers who make contributions for employees under a simple cafeteria plan from pension plan nondiscrimination requirements applicable to highly compensated and key employees.
Medicare/Medicaid
• Medicare Part D Discounts. In order to make prescription drug coverage more affordable for Medicare enrollees, the new law will provide a 50 percent discount on all brand-name drugs and biologics in the “donut hole.” It also begins phasing in additional discounts on brand-name and generic drugs to completely fill the donut hole by 2020 for all Part D enrollees.
• Additional Preventive Health Coverage. The new law provides a free, annual wellness visit and personalized prevention plan services for Medicare beneficiaries and eliminates cost-sharing for preventive services beginning in 2011.
Fees and Taxes
• Increased Tax on Withdrawals from HSAs and Archer MSAs. The health care reform law will increase the additional tax on HSA withdrawals prior to age 65 that are not used for qualified medical expenses from 10 to 20 percent. The additional tax for Archer MSA withdrawals not used for qualified medical expenses would increase from 15 to 20 percent.
2013
Health Plan Administration
• Administrative Simplification. Beginning in 2013, health plans must adopt and implement uniform standards and business rules for the electronic exchange of health information to reduce paperwork and administrative burdens and costs.
• Limiting Health Flexible Savings Account Contributions. The new health care law will limit the amount of contributions to health FSAs to $2,500 per year, indexed by CPI for subsequent years.
Fees and Taxes
• Eliminating Deduction for Medicare Part D Subsidy. Currently, employers that maintain prescription drug plans for their Medicare Part D eligible retirees are entitled to a tax deduction. This deduction will be eliminated in 2013.
• Increased Threshold for Medical Expense Deductions. The health care reform law increases the income threshold for claiming the itemized deduction for medical expenses from 7.5 percent of income to 10 percent. However, individuals over 65 would be able to claim the itemized deduction for medical expenses at 7.5 percent of adjusted gross income through 2016.
• Additional Hospital Insurance Tax for High Wage Workers. The new law increases the hospital insurance tax rate by 0.9 percentage points on wages over $200,000 for an individual ($250,000 for married couples filing jointly). The tax is also expanded to include a 3.8 percent tax on net investment income in the case of taxpayers earning over $200,000 ($250,000 for joint returns).
• Medical Device Excise Tax. The law also establishes a 2.3 percent excise tax on the first sale for use of a medical device. Eye glasses, contact lenses, hearing aids, and any device of a type that is generally purchased by the public at retail for individual use are excepted from the tax.
2014
Coverage Mandates
• Individual Coverage Mandates. The health care reform legislation requires most individuals to obtain acceptable health insurance coverage or pay a penalty, beginning in 2014. The penalty will start at $95 per person for 2014 and increase each year. The penalty amount increases to $325 in 2015 and to $695 (or up to 2.5 percent of income) in 2016, up to a cap of the national average bronze plan premium. After 2016, dollar amounts are indexed. Families will pay half the penalty amount for children, up to a cap of $2,250 per family. Individuals may be eligible for an exemption from the penalty if they cannot obtain affordable coverage.
• Employer Coverage Mandates. Employers with 50 or more employees that do not offer coverage to their employees will be subject to penalties if one employee receives a government subsidy for health coverage. The penalty amount is up to $2,000 annually for each full-time employee, excluding the first 30 employees. Employers who offer coverage, but whose employees receive tax credits, will be subject to a fine of $3,000 for each worker receiving a tax credit, up to an aggregate cap of $2,000 per full-time employee. Employers will be required to report to the federal government on health coverage they provide.
Health Insurance Exchanges
The health care reform legislation provides for health insurance exchanges to be established in each state in 2014. Individuals and small employers will be able to shop for insurance through the exchanges. Small employers are those with no more than 100 employees. If a small employer later grows above 100 employees, it may still be treated as a small employer. Large employers with over 100 employees are to be allowed into the exchanges in 2017. Workers who qualify for an affordability exemption to the coverage mandate, but do not qualify for tax credits, can use their employer contribution to join an exchange plan.
Health Insurance Reform
Additional health insurance reform measures will be implemented beginning in 2014. Specifically, health insurance companies will not be permitted to:
• Refuse to sell or renew policies due to an individual’s health status;
• Exclude coverage for treatments based on pre-existing health conditions;
• Charge higher rates due to heath status, gender or other factors (premiums will be able to vary based only on age (no more than 3:1), geography, family size, and tobacco use);
• Impose annual limits on the amount of coverage an individual may receive; or
• Drop coverage because an individual chooses to participate in a clinical trial for cancer or other life-threatening diseases or deny coverage for routine care that they would otherwise provide just because an individual is enrolled in such a clinical trial.
Fees and Taxes
• Individual Health Care Tax Credits. The new law makes premium tax credits available through the exchanges to ensure people can obtain affordable coverage. Credits are available for people with incomes above Medicaid eligibility and below 400 percent of poverty level who are not eligible for or offered other acceptable coverage. The credits apply to both premiums and cost-sharing.
• Small Business Tax Credit. The second phase of the small business tax credit for qualified small employers will be implemented in 2014. These employers can receive a credit for contributions to purchase health insurance for employees, up to 50 percent of premiums.
• Health Insurance Provider Fee. The health care reform law imposes an annual, non-deductible fee on the health insurance sector, allocated across the industry according to market share. The fee does not apply to companies whose net premiums written are $25 million or less.
2018
High-Cost Plan Excise Tax
A 40 percent excise tax is to be imposed on the excess benefit of high cost employer-sponsored health insurance (also known as a “Cadillac tax”). The annual limit for purposes of calculating the excess benefits is $10,200 for individuals and $27,500 for other than individual coverage. Responsibility for the tax is on the “coverage provider” which can be the insurer, the employer, or a third-party administrator. There are a number of exceptions and special rules for high coverage cost states and different job classifications.
This Legislative Brief provides a timeline of the implementation of key reform provisions that affect employers and individuals. Please read below for more information and contact Grant Davis GDI, with any questions about how you can prepare for health care reform.
2010
Expanded Insurance Coverage
The health care reform law contains some provisions designed to provide immediate improvements in access to health care coverage.
• Extended Coverage for Young Adults. Group health plans and health insurance issuers offering group or individual health insurance coverage that provides dependent coverage of children must make coverage available for adult children up to age 26. There is no requirement to cover the child of a dependent child. This requirement will apply to grandfathered and new plans.
Note: a “grandfathered plan” is one in which an individual was enrolled on March 23, 2010, and to which there is no change to existing coverage. Many requirements of the new law do not apply to grandfathered plans and nothing in the law requires individuals terminate coverage in which they were enrolled when the law was passed. A plan can still be a grandfathered plan even if family members or new employees are allowed to join.
• Access to Insurance for Uninsured Individuals with Pre-Existing Conditions. The health care reform bill provides for the establishment of a temporary high risk health insurance pool program to provide health insurance coverage for certain uninsured individuals with pre-existing conditions. The program will end when the health insurance exchanges, set to be established in 2014, are operational.
• Identifying Affordable Coverage. The Secretary of Health and Human Services is required to establish an Internet website through which residents of any state may identify affordable health insurance coverage options in that state. The website will also include information for small businesses about available coverage options, reinsurance for early retirees, small business tax credits, and other information of interest to small businesses. So-called “mini-med” or limited-benefit plans will be precluded from listing their policies on this website.
• Reinsurance for Covering Early Retirees. The new law requires the establishment of a temporary reinsurance program to provide reimbursement to participating employment-based plans for a portion of the cost of providing health insurance coverage to early retirees and their spouses, surviving spouses and dependents. This program will end on January 1, 2014.
Health Insurance Reform
The new law also imposes requirements on health insurance issuers to reform certain insurance practices and improve the coverage available.
• Eliminating Pre-Existing Condition Exclusions for Children. Group health plans and health insurance issuers may not impose pre-existing condition exclusions on coverage for children. This provision will apply to all employer plans and new plans in the individual market. This provision will also apply to adults in 2014.
• Coverage of Preventive Health Services. Group health plans and health insurance issuers offering group or individual health insurance coverage must provide coverage for preventive services. These plans also may not impose cost sharing requirements for preventive services.
• Prohibiting Rescissions. The health care reform law is designed to prohibit abusive rescissions of coverage by insurance companies when an individual gets sick as a way of avoiding covering the cost of the individual’s health care needs. Group health plans and health insurance issuers offering group or individual insurance coverage may not rescind coverage once the enrollee is covered, except in cases of fraud or intentional misrepresentation. Plan coverage may not be cancelled without prior notice to the enrollee. This provision applies to all new and existing plans.
• Limits on Lifetime and Annual Limits. In general, group health plans and health insurance issuers offering group or individual health insurance coverage may not establish lifetime limits on the dollar value of benefits for any participant or beneficiary or impose unreasonable annual limits on the dollar value of benefits for any participant or beneficiary. This requirement applies to all plans. Annual limits will also be prohibited beginning in 2014.
Health Plan Administration
In addition to any administrative changes required by the coverage improvements described above, health plans will be subject to increased administrative duties under health care reform.
• Improved Appeals Process. Group health plans and health insurance issuers offering group or individual health insurance coverage must implement an effective appeals process for appeals of coverage determinations and claims. At a minimum, plans and issuers must:
o have an internal claims process in effect;
o provide notice to enrollees, in a culturally and linguistically appropriate manner, of available internal and external appeals processes, and the availability of any applicable office of health insurance consumer assistance or ombudsman to assist them with the appeals processes; and
o allow enrollees to review their files, to present evidence and testimony as part of the appeals process, and to receive continued coverage pending the outcome of the appeals process.
The internal claims process must initially incorporate the current claims procedure regulations issued by the Department of Labor in 2001. Plans and issuers must also implement an external review process that meets applicable state requirements and guidance that is to be issued.
• Nondiscrimination Rules for Fully-Insured Plans. Fully-insured group health plans will now have to satisfy nondiscrimination rules regarding eligibility to participate in the plan and eligibility for benefits. These rules prohibit discrimination in favor of highly compensated individuals. This section does not appear to apply to grandfathered plans.
Medicare/Medicaid
The health care reform law will further affect individuals by making certain changes to Medicare and Medicaid.
• Rebates for the Medicare Part D “Donut Hole.” Currently, there is a gap in Medicare prescription drug coverage. The coverage gap falls between $2,830 and $6,440 in total drug spending. The health care reform bill provides a $250 rebate check for all Medicare Part D enrollees who enter the “donut hole.” Beginning in 2011, a 50 percent discount on brand-name drugs will be instituted and generic drug coverage will be provided in the donut hole. The donut hole gap will be filled by 2020.
• Medicaid Flexibility for States. States are given a new option under the health care reform law to cover additional individuals under Medicare. States will be able to cover parents and childless adults up to 133 percent of the Federal Poverty Level (FPL).
Fees and Taxes
With a total estimated cost of over $900 billion dollars, the reform of the nation’s health care system comes with additional costs and fees. These fees will also be implemented over the next several years. However, health care reform also includes some subsidies, in the form of tax credits, to help individuals and businesses pay for coverage.
• Small Business Tax Credit. The first phase of the small business tax credit for qualified small employers begins in 2010. These employers can receive a credit for contributions to purchase health insurance for employees. The credit is up to 35 percent of the employer’s contribution to provide health insurance for employees. There is also up to a 25 percent credit for small nonprofit organizations. When health insurance exchanges are operational, tax credits will increase, up to 50 percent of premiums.
• Indoor Tanning Services Tax. One additional tax imposed by the health care reform law is a 10 percent tax on amounts paid for indoor sun tanning services.
2011
Expanded Insurance Coverage
• Voluntary Long-Term Care Insurance Options. The health care reform law creates a long-term care insurance program for adults who become disabled. Participation will be voluntary and the program is to be funded by voluntary payroll deductions to provide benefits to adults who become disabled.
Health Plan Administration
• Improving Medical Loss Ratios. Health insurance issuers offering group or individual health insurance coverage (including grandfathered health plans) must annually report on the share of premium dollars spent on health care and provide consumer rebates for excessive medical loss ratios.
• Reporting Health Coverage Costs on Form W-2. Beginning in 2011, employers will be required to disclose the value of the health coverage provided by the employer to each employee on the employee’s annual Form W-2.
• Standardizing the Definition of Qualified Medical Expenses. The health care reform law conforms to the definition of “qualified medical expenses” for HSAs, FSAs and HRAs to the definition used for the itemized tax deduction. An exception to this rule is included so that amounts paid for over-the-counter medicine with a prescription still qualify as medical expenses. Costs for over-the-counter medications obtained without a prescription would not qualify.
• Cafeteria Plan Changes. The new law creates a Simple Cafeteria Plan to provide a vehicle through which small businesses can provide tax‐free benefits to their employees. This plan is designed to ease the small employer’s administrative burden of sponsoring a cafeteria plan. The provision also exempts employers who make contributions for employees under a simple cafeteria plan from pension plan nondiscrimination requirements applicable to highly compensated and key employees.
Medicare/Medicaid
• Medicare Part D Discounts. In order to make prescription drug coverage more affordable for Medicare enrollees, the new law will provide a 50 percent discount on all brand-name drugs and biologics in the “donut hole.” It also begins phasing in additional discounts on brand-name and generic drugs to completely fill the donut hole by 2020 for all Part D enrollees.
• Additional Preventive Health Coverage. The new law provides a free, annual wellness visit and personalized prevention plan services for Medicare beneficiaries and eliminates cost-sharing for preventive services beginning in 2011.
Fees and Taxes
• Increased Tax on Withdrawals from HSAs and Archer MSAs. The health care reform law will increase the additional tax on HSA withdrawals prior to age 65 that are not used for qualified medical expenses from 10 to 20 percent. The additional tax for Archer MSA withdrawals not used for qualified medical expenses would increase from 15 to 20 percent.
2013
Health Plan Administration
• Administrative Simplification. Beginning in 2013, health plans must adopt and implement uniform standards and business rules for the electronic exchange of health information to reduce paperwork and administrative burdens and costs.
• Limiting Health Flexible Savings Account Contributions. The new health care law will limit the amount of contributions to health FSAs to $2,500 per year, indexed by CPI for subsequent years.
Fees and Taxes
• Eliminating Deduction for Medicare Part D Subsidy. Currently, employers that maintain prescription drug plans for their Medicare Part D eligible retirees are entitled to a tax deduction. This deduction will be eliminated in 2013.
• Increased Threshold for Medical Expense Deductions. The health care reform law increases the income threshold for claiming the itemized deduction for medical expenses from 7.5 percent of income to 10 percent. However, individuals over 65 would be able to claim the itemized deduction for medical expenses at 7.5 percent of adjusted gross income through 2016.
• Additional Hospital Insurance Tax for High Wage Workers. The new law increases the hospital insurance tax rate by 0.9 percentage points on wages over $200,000 for an individual ($250,000 for married couples filing jointly). The tax is also expanded to include a 3.8 percent tax on net investment income in the case of taxpayers earning over $200,000 ($250,000 for joint returns).
• Medical Device Excise Tax. The law also establishes a 2.3 percent excise tax on the first sale for use of a medical device. Eye glasses, contact lenses, hearing aids, and any device of a type that is generally purchased by the public at retail for individual use are excepted from the tax.
2014
Coverage Mandates
• Individual Coverage Mandates. The health care reform legislation requires most individuals to obtain acceptable health insurance coverage or pay a penalty, beginning in 2014. The penalty will start at $95 per person for 2014 and increase each year. The penalty amount increases to $325 in 2015 and to $695 (or up to 2.5 percent of income) in 2016, up to a cap of the national average bronze plan premium. After 2016, dollar amounts are indexed. Families will pay half the penalty amount for children, up to a cap of $2,250 per family. Individuals may be eligible for an exemption from the penalty if they cannot obtain affordable coverage.
• Employer Coverage Mandates. Employers with 50 or more employees that do not offer coverage to their employees will be subject to penalties if one employee receives a government subsidy for health coverage. The penalty amount is up to $2,000 annually for each full-time employee, excluding the first 30 employees. Employers who offer coverage, but whose employees receive tax credits, will be subject to a fine of $3,000 for each worker receiving a tax credit, up to an aggregate cap of $2,000 per full-time employee. Employers will be required to report to the federal government on health coverage they provide.
Health Insurance Exchanges
The health care reform legislation provides for health insurance exchanges to be established in each state in 2014. Individuals and small employers will be able to shop for insurance through the exchanges. Small employers are those with no more than 100 employees. If a small employer later grows above 100 employees, it may still be treated as a small employer. Large employers with over 100 employees are to be allowed into the exchanges in 2017. Workers who qualify for an affordability exemption to the coverage mandate, but do not qualify for tax credits, can use their employer contribution to join an exchange plan.
Health Insurance Reform
Additional health insurance reform measures will be implemented beginning in 2014. Specifically, health insurance companies will not be permitted to:
• Refuse to sell or renew policies due to an individual’s health status;
• Exclude coverage for treatments based on pre-existing health conditions;
• Charge higher rates due to heath status, gender or other factors (premiums will be able to vary based only on age (no more than 3:1), geography, family size, and tobacco use);
• Impose annual limits on the amount of coverage an individual may receive; or
• Drop coverage because an individual chooses to participate in a clinical trial for cancer or other life-threatening diseases or deny coverage for routine care that they would otherwise provide just because an individual is enrolled in such a clinical trial.
Fees and Taxes
• Individual Health Care Tax Credits. The new law makes premium tax credits available through the exchanges to ensure people can obtain affordable coverage. Credits are available for people with incomes above Medicaid eligibility and below 400 percent of poverty level who are not eligible for or offered other acceptable coverage. The credits apply to both premiums and cost-sharing.
• Small Business Tax Credit. The second phase of the small business tax credit for qualified small employers will be implemented in 2014. These employers can receive a credit for contributions to purchase health insurance for employees, up to 50 percent of premiums.
• Health Insurance Provider Fee. The health care reform law imposes an annual, non-deductible fee on the health insurance sector, allocated across the industry according to market share. The fee does not apply to companies whose net premiums written are $25 million or less.
2018
High-Cost Plan Excise Tax
A 40 percent excise tax is to be imposed on the excess benefit of high cost employer-sponsored health insurance (also known as a “Cadillac tax”). The annual limit for purposes of calculating the excess benefits is $10,200 for individuals and $27,500 for other than individual coverage. Responsibility for the tax is on the “coverage provider” which can be the insurer, the employer, or a third-party administrator. There are a number of exceptions and special rules for high coverage cost states and different job classifications.
Guide To Developing Business Contingency Plan, Grant Davis GDI
This is a great overview of the basics! Just call Grant Davis GDI, and I'll help you get yours set up. Just one of the free services we offer our clients!
PLAN COMPONENTS
The following is guidance for developing your Business Continuity Plan. It includes the basic components of a Plan and outlines the steps in developing and implementing the Plan.
Executive Summary
The executive summary gives management a brief overview of: the purpose of the plan; the facility's emergency management policy; authorities and responsibilities of key personnel; the types of emergencies that could occur; and where response operations will be managed.
Emergency Management Elements
This section of the plan briefly describes your approach to the core elements of emergency management, which are:
a. Direction and control
b. Communications
c. Life safety
d. Property protection
e. Community outreach
f. Recovery and restoration
g. Administration and logistics.
These elements are the foundation for the emergency procedures that your facility will follow to protect personnel and equipment, and resume operations.
Emergency Response Procedures
The procedures spell out how the facility will respond to emergencies. Whenever possible, develop them as a series of checklists that can be quickly accessed by senior management, department heads, response personnel and employees.
Determine what actions would be necessary to:
a. Assess the situation;
b. Protect employees, customers, visitors, equipment, vital records and other assets, particularly during the first three days; and
c. Get the business back up and running.
Specific procedures might be needed for any number of situations such as bomb threats or tornadoes, and for such functions as:
a. Warning employees and customers
b. Communicating with personnel and community responders
c. Conducting an evacuation and accounting for all persons in the facility
d. Managing response activities
e. Activating and operating an emergency operations center
f. Fighting fires
g. Shutting down operations
h. Protecting vital records
i. Restoring operations
Support Documents - Documents that could be needed in an emergency include:
- Emergency call lists — lists (wallet size if possible) of all persons on and off site who would be involved in responding to an emergency, their responsibilities and their 24-hour telephone numbers
- Building and site maps that indicate:
a. Utility shutoffs
b. Water hydrants
c. Water main valves
d. Water lines
e. Gas main valves
f. Gas lines
g. Electrical cutoffs
h. Electrical substations
i. Storm drains
j. Sewer lines
k. Location of each building (include name of building, street name and number)
l. Floor plans
m. Alarm and enunciators
n. Fire extinguishers
o. Fire suppression systems
p. Exits
q. Stairways
r. Designated escape routes
s. Restricted areas
t. Hazardous materials (including cleaning supplies and chemicals)
u. High-value items
- Resource lists — Lists of major resources (equipment, supplies, services) that could be needed in an emergency; mutual aid agreements with other companies and government agencies.
THE DEVELOPMENT PROCESS
1. Identify challenges and prioritize activities - Determine specific goals and milestones. Make a list of tasks to be performed, by whom and when. Determine how you will address problem areas and resource shortfalls.
2. Write the Plan - Assign each member of the planning group a section to write. Determine the most appropriate format for each section.
3. Establish an aggressive timeline with specific goals - Provide enough time for completion of work, but not so much as to allow assignments to linger. Establish a schedule for:
a. First draft
b. Review
c. Second draft
d. Conduct tabletop exercise (see step 7)
e. Final draft
f. Printing
g. Distribution
4. Establish a training schedule - Have one person or department responsible for developing a training schedule for your facility.
5. Coordinate with outside organizations - Meet periodically with local government agencies and community organizations. Inform appropriate government agencies that you are creating an emergency management plan. While their official approval may not be required, they will likely have valuable insights and information to offer.
Determine State and local requirements for reporting emergencies, and incorporate them into your procedures.
Determine protocols for turning control of a response over to outside agencies. Some details that may need to be worked out are:
a. Which gate or entrance will responding units use?
b. Where and to whom will they report?
c. How will they be identified?
d. How will facility personnel communicate with outside responders?
e. Who will be in charge of response activities?
Determine what kind of identification authorities will require to allow your key personnel into your facility during an emergency.
6. Maintain contact with other corporate offices - Communicate with other offices and divisions in your company to learn:
a. Their emergency notification requirements
b. The conditions where mutual assistance would be necessary
c. How offices will support each other in an emergency
d. Names, telephone numbers and pager numbers of key personnel
Incorporate this information into your procedures.
7. Review, conduct training and revise - Distribute the first draft to group members for review. Revise as needed. For a second review, conduct a tabletop exercise with management and personnel who have a key emergency management responsibility. In a conference room setting, describe an emergency scenario and have participants discuss their responsibilities and how they would react to the situation. Based on this discussion, identify areas of confusion and overlap, and modify the plan accordingly.
8. Seek final approval- Arrange a briefing for the chief executive officer and senior management and obtain written approval.
9. Distribute the Plan - Place the final plan in three-ring binders and number all copies and pages. Each individual who receives a copy should be required to sign for it and be responsible for posting subsequent changes.
Determine which sections of the plan would be appropriate to show to government agencies (some sections may refer to corporate secrets or include private listings of names, telephone numbers or radio frequencies). Distribute the final plan to:
a. Chief executive and senior managers
b. Key members of the company's emergency response organization
c. Company headquarters
d. Community emergency response agencies (appropriate sections)
Have key personnel keep a copy of the plan in their homes. Inform employees about the plan and training schedule.
http://www.gdiinsurance.com/ http://www.ehealthinsurancegdi.com/
PLAN COMPONENTS
The following is guidance for developing your Business Continuity Plan. It includes the basic components of a Plan and outlines the steps in developing and implementing the Plan.
Executive Summary
The executive summary gives management a brief overview of: the purpose of the plan; the facility's emergency management policy; authorities and responsibilities of key personnel; the types of emergencies that could occur; and where response operations will be managed.
Emergency Management Elements
This section of the plan briefly describes your approach to the core elements of emergency management, which are:
a. Direction and control
b. Communications
c. Life safety
d. Property protection
e. Community outreach
f. Recovery and restoration
g. Administration and logistics.
These elements are the foundation for the emergency procedures that your facility will follow to protect personnel and equipment, and resume operations.
Emergency Response Procedures
The procedures spell out how the facility will respond to emergencies. Whenever possible, develop them as a series of checklists that can be quickly accessed by senior management, department heads, response personnel and employees.
Determine what actions would be necessary to:
a. Assess the situation;
b. Protect employees, customers, visitors, equipment, vital records and other assets, particularly during the first three days; and
c. Get the business back up and running.
Specific procedures might be needed for any number of situations such as bomb threats or tornadoes, and for such functions as:
a. Warning employees and customers
b. Communicating with personnel and community responders
c. Conducting an evacuation and accounting for all persons in the facility
d. Managing response activities
e. Activating and operating an emergency operations center
f. Fighting fires
g. Shutting down operations
h. Protecting vital records
i. Restoring operations
Support Documents - Documents that could be needed in an emergency include:
- Emergency call lists — lists (wallet size if possible) of all persons on and off site who would be involved in responding to an emergency, their responsibilities and their 24-hour telephone numbers
- Building and site maps that indicate:
a. Utility shutoffs
b. Water hydrants
c. Water main valves
d. Water lines
e. Gas main valves
f. Gas lines
g. Electrical cutoffs
h. Electrical substations
i. Storm drains
j. Sewer lines
k. Location of each building (include name of building, street name and number)
l. Floor plans
m. Alarm and enunciators
n. Fire extinguishers
o. Fire suppression systems
p. Exits
q. Stairways
r. Designated escape routes
s. Restricted areas
t. Hazardous materials (including cleaning supplies and chemicals)
u. High-value items
- Resource lists — Lists of major resources (equipment, supplies, services) that could be needed in an emergency; mutual aid agreements with other companies and government agencies.
THE DEVELOPMENT PROCESS
1. Identify challenges and prioritize activities - Determine specific goals and milestones. Make a list of tasks to be performed, by whom and when. Determine how you will address problem areas and resource shortfalls.
2. Write the Plan - Assign each member of the planning group a section to write. Determine the most appropriate format for each section.
3. Establish an aggressive timeline with specific goals - Provide enough time for completion of work, but not so much as to allow assignments to linger. Establish a schedule for:
a. First draft
b. Review
c. Second draft
d. Conduct tabletop exercise (see step 7)
e. Final draft
f. Printing
g. Distribution
4. Establish a training schedule - Have one person or department responsible for developing a training schedule for your facility.
5. Coordinate with outside organizations - Meet periodically with local government agencies and community organizations. Inform appropriate government agencies that you are creating an emergency management plan. While their official approval may not be required, they will likely have valuable insights and information to offer.
Determine State and local requirements for reporting emergencies, and incorporate them into your procedures.
Determine protocols for turning control of a response over to outside agencies. Some details that may need to be worked out are:
a. Which gate or entrance will responding units use?
b. Where and to whom will they report?
c. How will they be identified?
d. How will facility personnel communicate with outside responders?
e. Who will be in charge of response activities?
Determine what kind of identification authorities will require to allow your key personnel into your facility during an emergency.
6. Maintain contact with other corporate offices - Communicate with other offices and divisions in your company to learn:
a. Their emergency notification requirements
b. The conditions where mutual assistance would be necessary
c. How offices will support each other in an emergency
d. Names, telephone numbers and pager numbers of key personnel
Incorporate this information into your procedures.
7. Review, conduct training and revise - Distribute the first draft to group members for review. Revise as needed. For a second review, conduct a tabletop exercise with management and personnel who have a key emergency management responsibility. In a conference room setting, describe an emergency scenario and have participants discuss their responsibilities and how they would react to the situation. Based on this discussion, identify areas of confusion and overlap, and modify the plan accordingly.
8. Seek final approval- Arrange a briefing for the chief executive officer and senior management and obtain written approval.
9. Distribute the Plan - Place the final plan in three-ring binders and number all copies and pages. Each individual who receives a copy should be required to sign for it and be responsible for posting subsequent changes.
Determine which sections of the plan would be appropriate to show to government agencies (some sections may refer to corporate secrets or include private listings of names, telephone numbers or radio frequencies). Distribute the final plan to:
a. Chief executive and senior managers
b. Key members of the company's emergency response organization
c. Company headquarters
d. Community emergency response agencies (appropriate sections)
Have key personnel keep a copy of the plan in their homes. Inform employees about the plan and training schedule.
http://www.gdiinsurance.com/ http://www.ehealthinsurancegdi.com/
Grant Davis GDI Sample Privacy Notice
Just a sample. Call your GDI Insurance Broker We Give Our Clients All Their Compliance Requirements, and the lowest insurance rates! One call does it all 888-991-2929
[GROUP HEALTH PLAN NAME]
NOTICE OF PRIVACY PRACTICES
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
PLEASE REVIEW IT CAREFULLY.
Our Company's Pledge to You
This notice is intended to inform you of the privacy practices followed by the [Group Health Plan Name] (the Plan) and the Plan's legal obligations regarding your protected health information under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The notice also explains the privacy rights you and your family members have as participants of the Plan. It is effective on [date]. [Note: the effective date may not be earlier than the date on which the privacy notice is printed or otherwise published].
The Plan often needs access to your protected health information in order to provide payment for health services and perform plan administrative functions. We want to assure the plan participants covered under the Plan that we comply with federal privacy laws and respect your right to privacy. [Employer Name] requires all members of our workforce and third parties that are provided access to protected health information to comply with the privacy practices outlined below.
Protected Health Information
Your protected health information is protected by the HIPAA Privacy Rule. Generally, protected health information is information that identifies an individual created or received by a health care provider, health plan or an employer on behalf of a group health plan that relates to physical or mental health conditions, provision of health care, or payment for health care, whether past, present or future.
How We May Use Your Protected Health Information
Under the HIPAA Privacy Rule, we may use or disclose your protected health information for certain purposes without your permission. This section describes the ways we can use and disclose your protected health information.
Payment. We use or disclose your protected health information without your written authorization in order to determine eligibility for benefits, seek reimbursement from a third party, or coordinate benefits with another health plan under which you are covered. For example, a health care provider that provided treatment to you will provide us with your health information. We use that information in order to determine whether those services are eligible for payment under our group health plan.
Health Care Operations. We use and disclose your protected health information in order to perform plan administration functions such as quality assurance activities, resolution of internal grievances, and evaluating plan performance. For example, we review claims experience in order to understand participant utilization and to make plan design changes that are intended to control health care costs.
Treatment. Although the law allows use and disclosure of your protected health information for purposes of treatment, as a health plan we generally do not need to disclose your information for treatment purposes. Your physician or health care provider is required to provide you with an explanation of how they use and share your health information for purposes of treatment, payment, and health care operations.
As permitted or required by law. We may also use or disclose your protected health information without your written authorization for other reasons as permitted by law. We are permitted by law to share information, subject to certain requirements, in order to communicate information on health-related benefits or services that may be of interest to you, respond to a court order, or provide information to further public health activities (e.g., preventing the spread of disease) without your written authorization. We are also permitted to share protected health information during a corporate restructuring such as a merger, sale, or acquisition. We will also disclose health information about you when required by law, for example, in order to prevent serious harm to you or others.
Pursuant to your Authorization. When required by law, we will ask for your written authorization before using or disclosing your protected health information. If you choose to sign an authorization to disclose information, you can later revoke that authorization to prevent any future uses or disclosures.
To Business Associates. We may enter into contracts with entities known as Business Associates that provide services to or perform functions on behalf of the Plan. We may disclose protected health information to Business Associates once they have agreed in writing to safeguard the protected health information. For example, we may disclose your protected health information to a Business Associate to administer claims. Business Associates are also required by law to protect protected health information.
To the Plan Sponsor. We may disclose protected health information to certain employees of [Employer Name] for the purpose of administering the Plan. These employees will use or disclose the protected health information only as necessary to perform plan administration functions or as otherwise required by HIPAA, unless you have authorized additional disclosures. Your protected health information cannot be used for employment purposes without your specific authorization.
Your Rights
Right to Inspect and Copy. In most cases, you have the right to inspect and copy the protected health information we maintain about you. If you request copies, we will charge you a reasonable fee to cover the costs of copying, mailing, or other expenses associated with your request. Your request to inspect or review your health information must be submitted in writing to the person listed below. In some circumstances, we may deny your request to inspect and copy your health information. To the extent your information is held in an electronic health record, you may be able to receive the information in an electronic format.
Right to Amend. If you believe that information within your records is incorrect or if important information is missing, you have the right to request that we correct the existing information or add the missing information. Your request to amend your health information must be submitted in writing to the person listed below. In some circumstances, we may deny your request to amend your health information. If we deny your request, you may file a statement of disagreement with us for inclusion in any future disclosures of the disputed information.
Right to an Accounting of Disclosures. You have the right to receive an accounting of certain disclosures of your protected health information. The accounting will not include disclosures that were made (1) for purposes of treatment, payment or health care operations; (2) to you; (3) pursuant to your authorization; (4) to your friends or family in your presence or because of an emergency; (5) for national security purposes; or (6) incidental to otherwise permissible disclosures.
Your request to for an accounting must be submitted in writing to the person listed below. You may request an accounting of disclosures made within the last six years. You may request one accounting free of charge within a 12-month period.
Right to Request Restrictions. You have the right to request that we not use or disclose information for treatment, payment, or other administrative purposes except when specifically authorized by you, when required by law, or in emergency circumstances. You also have the right to request that we limit the protected health information that we disclose to someone involved in your care or the payment for your care, such as a family member or friend.
Your request for restrictions must be submitted in writing to the person listed below. We will consider your request, but in most cases are not legally obligated to agree to those restrictions. However, we will comply with any restriction request if the disclosure is to a health plan for purposes of payment or health care operations (not for treatment) and the protected health information pertains solely to a health care item or service that has been paid for out-of-pocket and in full.
Right to Request Confidential Communications. You have the right to receive confidential communications containing your health information. Your request for restrictions must be submitted in writing to the person listed below. We are required to accommodate reasonable requests. For example, you may ask that we contact you at your place of employment or send communications regarding treatment to an alternate address.
Right to be Notified of a Breach. You have the right to be notified in the event that we (or one of our Business Associates) discover a breach of your unsecured protected health information. Notice of any such breach will be made in accordance with federal requirements.
Right to Receive a Paper Copy of this Notice. If you have agreed to accept this notice electronically, you also have a right to obtain a paper copy of this notice from us upon request. To obtain a paper copy of this notice, please contact the person listed below.
Our Legal Responsibilities
We are required by law to protect the privacy of your protected health information, provide you with certain rights with respect to your protected health information, provide you with this notice about our privacy practices, and follow the information practices that are described in this notice.
We may change our policies at any time. In the event that we make a significant change in our policies, we will provide you with a revised copy of this notice. You can also request a copy of our notice at any time. For more information about our privacy practices, contact the person listed below.
If you have any questions or complaints, please contact:
[Individual's Name or Person's Title]
[Organization's Name]
[Street Address]
[City, State ZIP]
[Phone Number & E-mail Address]
Complaints
If you are concerned that we have violated your privacy rights, or you disagree with a decision we made about access to your records, you may contact the person listed above. You also may send a written complaint to the U.S. Department of Health and Human Services — Office of Civil Rights. The person listed above can provide you with the appropriate address upon request or you may visit www.hhs.gov/ocr for further information. You will not be penalized or retaliated against for filing a complaint with the Office of Civil Rights or with us.
This form does not constitute legal advice and is provided "as is." This form is based upon current federal law and is subject to change based upon changes in federal law or subsequent interpretive guidance. This form must be modified to reflect the user's privacy practices and its state law where the state law is more stringent.
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