I believe that this issue will be discussed on the following upcoming
audioconference:

HIPAA ADMINISTRATIVE SIMPLIFICATION, FEDERAL PREEMPTION & STATE LAW &
REGULATION 
Practical Guidance & Compliance Strategies
www.HIPAAAudioconferences.com

-- Wednesday, July 10, 2002
 7:00 am - 8:30 am H/AST (Hawaii-Aleutian)
 9:00 am - 10:30 am ADT (Alaska)
10:00 am - 11:30 am PDT (and Arizona)
11:00 am - 12:30 pm MDT
12:00 pm - 1:30 pm CDT
 1:00 pm - 2:30 pm EDT

FEATURES:

-- Mark Barnes, Esq., Partner, Ropes & Gray, Co-author, Practical Guidance
on HIPAA Preemption of State Laws: Analytical Framework & Preemption
Methodology (AHLA, 2002) & Former Associate Commissioner for Medicaid &
Legal Policy, New York City Dept of Health, New York NY

-- Bruce Merlin Fried, Esq., Partner, Shaw Pittman, Former Director, Center
for Health Plans & Providers, HCFA & Director, AAHP/HIAA HIPAA & State Law
Compliance Project, Washington DC

-- Joy Pritts, Esq., Sr Counsel, Health Privacy Project, Institute for
Healthcare Research & Policy, Georgetown University & Co-author, State of
Health Privacy: An Uneven Terrain (A Comprehensive Survey of State Health
Privacy Statutes), Washington DC

-- Jean O. Quarrier, Esq., Associate Counsel, Bureau of House Counsel, New
York State Department of Health, Albany, NY

-- Clark Stanton, Esq., Partner, Davis Wright Tremaine and Editor,
California Healthcare Association HIPAA Privacy Manual, San Francisco, CA

-- Alan S. Goldberg, Esq., Partner, Goulston & Storrs, Adjunct Professor,
Suffolk University Law School & University of Maryland School of Law,
Moderator, AHLA HIT Listserve & Director, ABA Health Law Section HIPAA &
State Law Project, Boston MA (Moderator)




-----Original Message-----
From: Tomak-Maurer, Tonya (Chicago)
[mailto:[EMAIL PROTECTED]]
Sent: Sunday, July 07, 2002 8:36 AM
To: '[EMAIL PROTECTED]'
Subject: State Preemption and ERISA


Anyone have any thoughts on HIPAA state pre-emption and ERISA.  I found the
below paragraph in a published article...any concurring or differing
opinions.

"In general, HIPAA preempts all state laws that establish privacy standards
that are contrary to the Privacy Rule.  However, state laws that are deemed
to be "more stringent" than the Privacy Rule are excepted from preemption by
HIPAA.  Therefore, the Privacy Rule establishes a "federal floor" approach
whereby many state privacy laws will continue in effect.  However, HIPAA
does not change the traditional preemption analysis under ERISA, whereby any
state law that "relates to" an employee benefit plan is preempted by ERISA,
except for insurance regulation.  Therefore, self-insured health plans
arguably would continue to be exempt from state privacy laws under current
ERISA preemption analysis leaving only insured health plans and health plans
exempt from ERISA (such as church and governmental plans) to be subject to
state laws that are more stringent than the Privacy Rule."

Thanks,
Tonya

W: 312.704.2494

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