Implementation of the Health Insurance Portability and Accountability Act (Public Law 104-191) raises numerous questions in how business will be performed within the various part of the Department of Veterans Affairs. Office of General Counsel provides advice to all organizations within VA about their legal obligations.
OGC issue ADV 3-2003 (Advisory Opinion) on March 17, 2003 to answer a list of questions submitted by Veterans Benefits Administration. Usually OGC Advisory opinions are not published as they are opinions dealing with internal VA operations and of limited interest to the public. In this instance, OGC has decided that although the opinion deals with internal operations issues it is of interest as well to the public and is posted for the public and Veterans' Service Organizations..
ADV 3-2003 (3/17/2003) Health Insurance Portability and Accountability Act Applicability in VBA