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<br />© 2019 Hitesman & Wold, P.A. MEDSURETY, LLC <br />Cafeteria Plan 1-888-816-4234, www.medsurety.com <br />Basic Plan Document <br />57 <br />(d) Implement reasonable and appropriate security measures to ensure that only those <br />persons identified below have access to ePHI and that such access is limited to the <br />purposes identified below. <br />16.4 Adequate separation between the Plan and the Employer must be maintained. In <br />accordance with HIPAA, only the following employees or classes of employees may be given <br />access to PHI: <br />(a) The person employed in the position that is given primary responsibility for performing <br />the Employer’s duties as the Plan Administrator of the Optional Benefits; and <br />(b) Staff designated by the person described in (a) above. <br />16.5 Limitation of PHI Access and Disclosure. The persons described above may only have <br />access to and use and disclose PHI for Plan administration functions that the Employer performs <br />for the Plan. <br />16.6 Noncompliance Issues. If a person described above does not comply with this Plan <br />document, the Employer shall provide a mechanism for resolving issues of noncompliance <br />including, but not limited to, disciplinary sanctions.