How to determine if you're responsible for meeting HIPAA requirements

In a nutshell, if your plan pays for the cost of medical care and/or submits health care transactions electronically, you might very well be considered a health plan that is a covered entity under HIPAA. I recommend that you check out the following Covered Entity Decision Tools page provided by the Centers for Medicare and Medicaid Services: http://www.cms.gov/hipaa/hipaa2/support/tools/decisionsupport/default.asp

Also, the American Medical Association has a "Who must comply test" that can provide you with some general guidance as well. Check it out at: http://www.ama-assn.org/ama/pub/category/8818.html