Group Health Plan Requirements¶
Last 1 Enterprises LLC / LastVet Safeguard category: Organizational HIPAA Security Rule citation: 45 CFR §164.314(b) Status: Scaffold (Bucket 1c). Not approved for enforcement until Ryan review.
Document metadata¶
| Field | Value |
|---|---|
| Policy owner | TODO (Ryan) |
| Version | 0.1-scaffold |
| Effective date | TODO (Ryan) |
| Review cadence | Annual (TODO: Ryan confirm) |
| Approver | TODO (Ryan) |
| Last reviewed | 2026-08-26 (scaffold only) |
1. Purpose¶
Address organizational requirements if the covered entity is a group health plan.
2. Scope¶
N/A unless Last 1 Enterprises operates as a group health plan.
3. Policy statements¶
- LastVet / Last 1 Enterprises does not operate as a group health plan as of this scaffold.
- If organizational status changes, this policy shall be revised with counsel before ePHI processing under plan sponsor rules.
- TODO (Ryan): Confirm with WSGR that LastVet BA/C covered-entity posture does not trigger §164.314(b) obligations.
4. Roles and responsibilities¶
| Role | Responsibility |
|---|---|
| Security Officer (Ryan) | TODO (Ryan): assign formal Security Rule responsible person per §164.308(a)(2) |
| Workforce members | TODO (Ryan): acknowledge policy when hired / annually |
| Contractors / BAs | TODO (Ryan): flow-down via BAA and agreements |
5. LastVet-specific context (from existing docs)¶
LastVet is a coordination platform and business associate to providers/VA pathways, not an employer group health plan. Document retained for Security Rule completeness.
6. Related documents¶
../HIPAA_ARCHITECTURE.md— asset inventory and data flows (Bucket 1a)../HIPAA_RISK_ANALYSIS.md— risk register (Bucket 1b)../../security/POSTURE.md— canonical security posture
7. Ryan TODO (substantive content deferred)¶
- Counsel confirmation to file in compliance folder.
- If status changes, add plan documents and certification requirements.