What Employers Need to Know About the Updated HIPAA Privacy Notice (Deadline: April 16, 2026)

A Required HIPAA Update Is Here-and the Deadline Is Close

A recent federal update to the standard HIPAA Privacy Notice means many employers need to take action—quickly.

This notice explains:

• How employee health information is protected
• What rights individuals have regarding their health data

The update introduces new requirements around how substance use treatment information must be handled, aligning with stricter federal protections.

Bottom line: If your organization sponsors certain health-related benefits, you likely need to update and redistribute your notice by April 16, 2026.

Who This Applies To

You’ll need to take action if your company offers:

• A Flexible Spending Account (FSA)
• A Health Reimbursement Arrangement (HRA)
• An Individual Coverage HRA (ICHRA)
• A fully insured plan where you have access to employee health/claims data

If your plans are fully insured and you do not access any protected health information (PHI), your insurance carrier will typically handle this requirement.

What Changed

The updated model notice now includes additional protections for substance use disorder (SUD) records, which come with stricter confidentiality requirements.

For example, these records generally cannot be used or disclosed for investigations or legal proceedings without explicit consent or a court order

This reinforces the importance of how sensitive health data is handled across employer-sponsored plans.

What You Need to Do (Simple Steps)

Here’s what compliance looks like:

1. Update Your HIPAA Privacy Notice- Download the updated version from HHS or use an editable version that can be provided by Fine Point- contact us!

2. Review Internal Policies- If you reference HIPAA notices in your policies, make sure they reflect the updated language.

3. Train Your Team (If Applicable)- Anyone with access to protected health information should receive a quick refresher. This is also a great time to ensure your team has completed HIPAA training.

4. Distribute the Updated Notice by April 16, 2026

You must provide this to:

• Active employees
• Employees on leave
• COBRA participants
• Anyone eligible for benefits

Important: This notice must be provided on paper, unless employees have explicitly agreed to electronic delivery (which most organizations do not have on file).

The Fine Point team can provide you with an Employee Message to use- just reach out to us- 877-535-1183.

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Don’t Overlook This Step: HIPAA Training

If employees in your organization have access to claims or health data, this update is a strong reminder to ensure they are properly trained.

If you need guidance on HIPAA training resources, the Fine Point team can help point you in the right direction.

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How Fine Point Can Help

If you’re unsure whether this applies to you, or want help implementing it, we can support:

• Reviewing your plan structure and obligations
• Providing an editable notice template
• Advising on distribution and compliance
• Recommending HIPAA training resources

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Final Takeaway

This isn’t a complex lift—but it is a time-sensitive one.

Updating and distributing your HIPAA Privacy Notice now ensures you stay compliant and avoid unnecessary risk.

Need help or have questions?

Reach out to your Fine Point team—we’re here to help.

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