HomeMy WebLinkAboutCORRESPONDENCE - RFP - P902 BENEFITSAMENDMENT #1 TO THE CITY OF FORT COLLINS
FLEXIBLE BENEFITS PLAN
REGARDING HIPAA SECURITY PROVISIONS
WHEREAS, the City of Fort Collins, as Plan Sponsor, has adopted the City of Fort Collins
Flexible Benefits Plan as amended and restated effective January 1, 2002 ("Plan"); and
WHEREAS, the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and the
regulations adopted pursuant thereto require that the Plan be amended to incorporate security
safeguard provisions for electronic protected health information.
NOW, THEREFORE, the Plan is hereby amended effective April 20, 2005, to add a new Article
XIII. HIPAA SECURITY COMPLIANCE, to read as follows:
ARTICLE XIll
HIPAA SECURITY COMPLIANCE
13.1 The City of Fort Collins ("Plan Sponsor") has implemented policies and
procedures to ensure that its creation, receipt, maintenance, or
transmission of electronic protected health information ("ePHI") on behalf
of the Plan complies with the applicable administrative, physical, and
technical safeguards required to protect the confidentiality and integrity of
electronic protected health information ("ePHI") under the Security
Standards 45 CFR Part 164 adopted pursuant to the Health Insurance
Portability and Accountability Act of 1996 ("HIPAA").
13.2 In accordance with HIPAA, only the following employees or classes of
employees of the Plan Sponsor may be given access to PHI:
l . The Benefits Administrator;
2. The Director of Human Resources;
3. The Benefits work group within the Human Resources
Department.
4. The Wellness Program Coordinator and Specialist; and
5. The employees who perform functions related to the City -
sponsored employee group health plans, including but not limited
to le�,,al and systems personnel.
13. The Plan will ensure that any agents, including a business Associate or
subcontractor, to whom the Plan Sponsor provides ePHI received from the
Plan agree to the same restrictions and conditions that apply to the Pia❑
Sponsor with respect to such ePHI;
1 ).4 If the persons described in Section 13.2 do not comply with the plan
document, the Plan Sponsor shall provide a mechanism for resolving
issues of noncompliance, including disciplinary sanctions.
13.5 The Plan will require any agents, including a Business Associate or
subcontractor, to whom the Plan Sponsor provides ePHI received from the
Plan, to notify the Plan of any Security violation to the Plan Sponsor.
ADOPTED this 13 day of April, 2005.
CITY OF FORT COLLINS, COL DO
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City Manager '
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APPROVED: APPROVED AS TO FORM:
Human Resources Director Assista City Attorney
AMENDMENT #2 TO THE CITY OF FORT COLLINS
GROUP HEALTH PLAN
REGARDING HIPAA SECURITY PROVISIONS
WHEREAS, the City of Fort Collins, as Plan Sponsor, has adopted the City of Tort Collins
Group Health Plan as amended and restated effective January 1. 2002 ("Plan"); and
WHEREAS, the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and the
reciulations adopted pursuant thereto require that the Plan be amended to incorporate security
safeguard provisions for electronic protected health information.
NOW, THEREFORE, the Plan is hereby amended effective April 20, 2005, to add a new Article
IX. HIPAA SECURITY COMPLIANCE, to read as follows:
ARTICLE IX
HIPAA SECURITY COMPLIANCE
9.1 The City of Fort Collins ("Plan Sponsor") has implemented policies and
procedures to ensure that its creation, receipt, maintenance, or
transmission of electronic protected health information ("ePHI") on behalf -
of the Plan complies with the applicable administrative, physical, and
technical safeguards required to protect the confidentiality and integrity of
electronic protected health information ("ePHI"} tinder the Security
Standards 45 CFR Part 164 adopted pursuant to the Health Insurance
Portability and Accountability Act of 1996 ("HIPAA").
9.2 In accordance with HIPAA, only the following employees or classes of
employees of the Plan Sponsor may be given access to PHI:
I . The Benefits Administrator;
2. The Director of Human Resources;
3. The Benefits work group within the Human Resources
Department.
4. The Wellness Program Coordinator and Specialist; and
5. The employees who perform functions related to the City -
sponsored employee group health plans, including but not limited
to legal and systems personnel.
9.3 The Plan will ensure that any agents, including a business Associate or
subcontractor, to whom the Plan Sponsor provides ePHI received from the
Plan aeree to the same restrictions and conditions that apply to the Plan
Sponsor with respect to such ePHI;
9.4 If the persons described in Section 9.2 do not comply with the plan
document, the Plan Sponsor shall provide a mechanism for resolving
issues of noncompliance, including disciplinary sanctions.
9.5 The Plan will require any agents, including a Business Associate or
subcontractor, to whom the Plan Sponsor provides ePHI received from the
Plan. to notify the Plan of any Security violation to the Plan Sponsor.
ADOPTED this %3 day of April, 2005.
CITY" OF FORT COLLINS. CpLORA O t :7
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APPROVED:
By:
Human Re ources Director
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City Clerk
ED AS TO FORM:
By:
Assista City Attorney