What Counts as PHI
Any health information tied to an individual and maintained or transmitted by a covered entity or business associate is PHI. Employers sponsoring self-funded health plans must ensure HR teams, brokers, and administrators only access PHI for plan administration purposes.
Core Compliance Pillars
- Administrative safeguards: Document policies for minimum necessary access, workforce training, and breach response.
- Physical safeguards: Secure paper files, restrict server rooms, and control workstation access.
- Technical safeguards: Use encryption, role-based access controls, and audit logs for all PHI systems.
2026 Action Plan
- Update your risk assessment to reflect hybrid work and new third-party integrations.
- Refresh Business Associate Agreements to account for remote services and cybersecurity responsibilities.
- Run tabletop exercises for breach notification to make sure you can meet the 60-day reporting window.
Prioritizing HIPAA now reduces exposure to OCR fines and protects employee trust. For Section 125 and benefits administration that respects privacy, contact us.