The following is not meant to be legal advice.
Under the Health Insurance Portability and Accountability Act (HIPAA), health plan sponsors have an obligation to remind participants about their HIPAA privacy rights at least once every three years. The reminder deadline for small-employer health plans (health plans that pay $5 million or less per year in claims or insurance premiums) is
The health insurance provider or health plan administrator should consider taking the steps necessary to ensure that the health plan remains in compliance with the HIPAA privacy regulations.
The reminder obligation may be satisfied by redistributing the privacy notice sent to participants or distributing a reminder notice including the procedure for requesting the privacy notice. The summary plan description for the health plan may contain a reminder. The failure to comply with the reminder rule may result in a civil penalty of up to $100 per participant (up to a maximum of $25,000 per calendar year) for sponsors.
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