Early last year, the Department of Health and Human Services issued final privacy and security regulations (Final Rule) under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The Final Rule, effective March 26, 2013, imposes significant responsibilities on group health plans and their business associates, which include subcontractors of such business associates. A “business associate” is any party providing services to an employer or its health plan that receives, or may receive, protected health information from the health plan. A health plan typically has multiple business associates, which can include insurers, administrative service providers, consultants, and claim administrators.