We are a corporate sales office who utilizes independent contractors as our sales force.  As their one and only benefit, we offer these people the opportunity to enroll in our dental plan.  We are getting ready to do our annual HIPAA training and I'm wondering it these people would need to be included since they are independent contractors?


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  • I don't think that you have any training obligation to these people. I looked into the issue of who has to get HIPPA training a while ago and it turns out that I had the same misconception that your question implies. The regulations say that employees of a covered entity must be trained about HIPAA privacy obligations. Covered entities are health care providers, health care plans, and health care clearing houses. I don't think that your company is a provider or clearing house, The only covered entities are the group health plans that the company sponsors. The individuals who must be trained are the employees of the health plans. While the health plans as such may not have any employees, but it is the company employees who do the work of the health plans and who come into contact with protected health information who must be trained about HIPAA requirements. Participants in health plans must be given information about HIPAA, but there is no requirement that I know of to give them training. For employers that are health care providers, it's a whole different ball game.
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