HIPAA Exhibit Instructions

In order to receive a HIPAA Certificate, two things must take place. First, an event must be entered into the HR system that will create a HIPAA Trigger. Once a HIPAA Trigger has been created, a second process will determine if an employee was enrolled in a HIPAA Qualifying Benefit at the time the triggering event took place.

In order to implement the HIPAA functionality at your site, several steps must be taken with your application to identify HIPAA triggering events and HIPAA Qualifying Benefits.

Identifying HIPAA Triggering Events

The Government Regulators have identified the following events that must be setup as HIPAA Triggering Events:

• Termination of an Employee

• Death of an Employee

• Employee Enrolls in Medicare

• Divorce or Legal Separation

• Dependent Coming of Age

• COBRA Coverage Ending

Functional Setup Required for HIPAA processing

1. Identify the Personnel Action Codes that your site has established for Termination of an Employee, Death of an Employee, and Employee Enrolls in Medicare.

2. On the Personnel Action (PACT) page, update these Personnel Action Codes by setting the HIPAA Certificate Flag indicator to ‘Y’, for YES.

Once these Personnel Action Codes have been modified, anytime an Employee Status Maintenance (ESMT) transaction or an Agency Specific and Accounting Data (AGYS) transactions takes place using one of these Codes, a HIPAA Trigger will be created.

Additionally, anytime a change is made to the Divorce / Separation Date on the Dependent Profile (DPND) for the Spouse of an Employee, a HIPAA Trigger will be created. No additional setup is required to implement this functionality.

On a monthly basis, the Dependent Coming of Age (HB07000M) procedure should be executed to create HIPAA Triggers for any Dependents who will soon reach the COBRA Age Limit for creditable coverage. If your site participates in COBRA, this procedure should already be a part of your Monthly processing. HIPAA Triggers will be created based upon the same Age Limit and Tickler Days currently identified in the HB07000M job stream. No additional setup is required to implement this functionality.

The COBRA Coverage Ending - HIPAA Process (HH07100M) procedure should be added as part of your Monthly processing. This batch job will create HIPAA Triggers for any Employees currently enrolled in COBRA whose COBRA Coverage will soon be coming to an end. The COBRA Coverage Ending - HIPAA Program selects COBRA_MASTER table records when the coverage end date is between the batch parameter's Start and End Date. Typically, the Range Start Date (in the format CCYYMMDD) should be first day of the month, and the Range End Date (also in the CCYYMMDD format) should be the last day of the month. HIPAA Triggers are created for all employees currently enrolled in COBRA whose coverage will be ending or has ended during the range of dates provided in the parameters.

Identifying HIPAA Qualifying Benefits

As part of the implementation of the HIPAA process, your site must identify the Employee Fringe Benefits offered that should qualify for HIPAA Certificates.

Functional Setup Required for HIPAA Processing:

1. Create a list of all Employee Fringe Benefits that should qualify for HIPAA Certificates.

2. On the Benefit Report Control (BRCT) page, create a Benefit Report ID called ‘HIPAA’.

3. Once you have the list of Fringe Benefits that you have determined will be HIPAA eligible, identify the Benefit Type Class Codes for these Benefits. This information will be available on the Employee Fringe Benefit Type (BENT) page.

4. Update the Benefit Type Class Code (BTCL) page for each of the codes you have selected to include at least one Benefit Report ID of ‘HIPAA’.  

Note: As a general rule, you will find that most of the BTCL codes that have been identified as a Class Covered By COBRA, will also be HIPAA Eligible Benefit Classes.