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ARTICLE · 04 SEPTEMBER 2013

Employee Benefits Update – August 2013

Reinhart, Boerner, Van Deuren SC
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Before September 24, 2013, all business associate agreements entered into after January 25, 2013 must be updated to comply with the final rule implementing the Health Information Technology for Economic and Clinical Health.

United StatesEmployment and HR
Steven Huff
Steven Huff
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SELECT COMPLIANCE DEADLINES AND REMINDERS

Business Associate Agreements Entered into in 2013 Must Be Revised Before September 24, 2013

Before September 24, 2013, all business associate agreements (BA) entered into after January 25, 2013 must be updated to comply with the final rule implementing the Health Information Technology for Economic and Clinical Health (HITECH). However, BAs that were entered into prior to January 25, 2013 and were compliant at the time of execution need not be revised for HITECH until September 23, 2014.

2013 Participant Fee Disclosure Can Be Delayed

As described in more detail below, the Department of Labor (DOL) has formally permitted plan sponsors to delay the 2013 participant fee disclosure by up to six months to allow plan sponsors to align the annual distribution deadline with other plan disclosures, like participant benefit statements or annual enrollment materials.

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