What programs are small health plans and when must they comply with HIPAA?
Health plans with $5 million or less in annual receipts are small health plans. The statewide Wisconsin Well Woman Program and statewide WisconCare are considered to be small health plans. Each county General Relief Medical program may be a small health plan if annual receipts are $5 million or less. Each county is considered a separate program and the $5 million test can be applied at the county level. Other county and city funded programs may be health plans, and would qualify as small health plans if they meet the annual receipts test. Counties and cities should consult with their legal counsels for determinations on specific programs. Small health plans have until April 14, 2004, to comply with the Privacy Rule. They have until October 16, 2003, to comply with the Electronic Code Sets and Transactions Rule, regardless of whether they filed for an extension.
