As the ACA Administrative Simplification provisions build on and update the provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), ACA Section 1104 requires all HIPAA-covered entities to comply with the ACA-mandated standards and applicable operating rules by their compliance dates. The CMS website provides charts to help organizations determine whether an organization or individual is a HIPAA-covered entity.
NOTE: ACA Section 1104 also mandates a certification process for health plans only to demonstrate compliance with the ACA-mandated operating rules.