Skip to content

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

  1. LastVet / Last 1 Enterprises does not operate as a group health plan as of this scaffold.
  2. If organizational status changes, this policy shall be revised with counsel before ePHI processing under plan sponsor rules.
  3. 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.

7. Ryan TODO (substantive content deferred)

  • Counsel confirmation to file in compliance folder.
  • If status changes, add plan documents and certification requirements.