The Trust's business associates who perform electronic transactions on its behalf are required to follow certain HIPAA standards and operating rules. A recently published proposed rule introduces a new requirement to submit compliance certification for three specific types of electronic transactions: (1) eligibility, (2) claim status, and (3) electronic fund transfers. A one-time certification must be submitted to the Department of Health and Human Services between January 1, 2015 and December 2015.

The Trust is responsible for obtaining certification even though the HIPAA covered electronic transactions are performed by its business associates. The penalty for each day of noncompliance is substantial: $1 per covered life per day.