MIB Member Compliance

Latest News!

  • MIB makes special announcements concerning upcoming changes to the MIB Authorization.

  • MIB has developed an updated Business Associate Agreement ("BAA") in order to meet the requirements of the HITECH Act. MIB has tailored its new BAA to reflect the changes required by the HITECH Act and to account for the unique relationship that exists between MIB and its valued Member companies. 

MIB has also made available an agreement for those Members who find it necessary to comply with the new MA regulation (eff. 3-1-10) on Protection of Personal Information.

To obtain access to the new BAA and other Member Compliance documents, please contact:

Allyson Roklan
Associate General Counsel
MIB Group, Inc.
781-751-6321
aroklan@mib.com


Partnering with Compliance Professionals at Member Companies

MIB has successfully operated an information exchange with its Members for over 109 years. The MIB information exchange is conducted in conformity with longstanding General Rules that require the protection and safeguarding of confidential consumer medical information. While Medical Directors and Chief Underwriters have traditionally taken responsibility for Member compliance with MIB's General Rules, MIB now partners with compliance professionals at Member companies. This partnership addresses efforts to comply with the federal Fair Credit Reporting Act, as amended by the Fair and Accurate Credit Transactions Act (and regulations promulgated thereunder), state and federal privacy and insurance laws, and regulations under each.

MIB's Regulatory Environment

MIB is deeply committed to providing its services to Member life and health insurance companies in a manner that allows their full compliance with applicable laws protecting the privacy and security of consumer information, including Gramm-Leach-Bliley Act, the Privacy and Security Rules promulgated by the Department of Health and Human Services under the Health Insurance Portability and Accountability Act ("HIPAA"), and numerous state privacy laws, including the NAIC Model Insurance Information and Privacy Act.

Classified as a "nationwide specialty consumer reporting agency," MIB is directly regulated under the federal Fair Credit Reporting Act ("FCRA"), which was enacted by Congress in 1970 to promote accuracy, fairness, and the privacy of personal information assembled by "consumer reporting agencies." Since 1974, MIB has required all Members to comply with its rules as they relate to the FCRA regardless if the Member is a United States or Canadian domiciled insurance company. Because MIB's operations are regulated as a consumer reporting agency under FCRA, it provides both Canadian and US consumers with the rights, protections and privileges available under FCRA without any differentiation based on residence, citizenship or other nexus. In short, MIB conducts its operations throughout North America with a consistently high degree of confidentiality and security.

MIB has many Canadian Members and, accordingly, it receives "personal information" about Canadian insureds. The collection, use and disclosure of such personal information is governed by the Personal Information Protection and Electronic Documents Act ("PIPEDA") and provincial laws such as "An Act Respecting the Protection of Personal Information in the Private Sector" in Quebec. MIB has agreed to protect such information in a manner that is substantially similar to each of its Canadian Members' privacy and security practices, and in accordance with applicable laws.

Recent Compliance Issues and Initiatives

MIB has recently provided guidance to Members on various topics that may be of interest to compliance professionals at Member companies. These documents are protected. To obtain access, contact Nancy Donofrio.

Contacts

Jonathan W. Sager
Vice President, General Counsel & Secretary,
Chief Privacy Officer and Chief Security Officer
MIB Group, Inc.
781-751-6332
jsager@mib.com

Allyson Roklan
Associate General Counsel
MIB Group, Inc.
781-751-6321
aroklan@mib.com