ØGenerally, employer (Plan Sponsor) is not a HIPAA "Covered Entity" - Health Plan is. For fully insured plans, this typically means health insurer, HMO, EAP provider, etc. ØAs Covered Entities, health plans bear brunt of compliance requirements (your responsibilities become exponentially larger as quantity of data you receive increases) ØMeet with every service provider, or ensure that your broker or consultant has reviewed compliance requirements with each ØUse protected health information only for needed administration of benefit programs (HIPAAspeak: "Treatment, Payment and Health Care Operations) ØCollect (and release) only minimum data required to "do job" (e.g. enroll an employee, file claims, etc.) ØRestrict data to those persons who absolutely must use it ØEstablish "firewalls" and safeguards to protect data (separate locked files, restricted access, password protect systems) ØAppoint a Privacy Official (not required for fully insured plans that never receive PHI) ØCreate a Privacy Policy and distribute a Privacy Notice to participants Ø"Scrub" personally identifiable data from communications pieces, ID Cards, etc.

HIPAA, like COBRA before it, will continually change as new rules and regulations are released (for example, U.S. Dept. of HHS has yet to release enforcement rules for HIPAA). Ongoing compliance will require vigilance in remaining up to date on changing laws. It's vital your broker/consultant proactively work with your organization to review plans, identify problems and provide ongoing education to maximize performance of your benefit plans.

Then you must carefully select which of above becomes your corrective public relations goal -- clarify misconception, spike that rumor, correct false assumption or fix certain other inaccuracies.

You can achieve your goal by picking right strategy from three choices available to you. Change existing perception, create perception where there may be none, or reinforce it. But be sure your new strategy fits comfortably with your new public relations goal.

But what will you say when you have opportunity to address your key stakeholder audience to help persuade them to your way of thinking?

Select your best writer to prepare message because s/he must put together some very special, corrective language. Words that are not only compelling, persuasive and believable, but clear and factual if they are to shift perception/opinion towards your point of view and lead to behaviors you have in mind.

Happily, next step is easy. You select communications tactics to carry your message to attention of your target audience. Making certain that tactics you select have a record of reaching folks like your audience members, you can pick from dozens that are available. From speeches, facility tours, emails and brochures to consumer briefings, media interviews, newsletters, personal meetings and many others.

Since how one communicates often affects credibility of message, you may wish to deliver it in small getogethers like meetings and presentations rather than through a higher- profile media announcement.

You’ll soon feel pressure for signs of progress. And that means a second perception monitoring session with members of your external audience. Employing many of same questions used in first benchmark session, you will now be watching carefully for signs that offending perception is being altered in your direction.

Luckily, matters can be accelerated by adding more communications tactics as well as increasing their frequencies.

This workable public relations blueprint will help you persuade your most important outside stakeholders to your way of thinking, then move them to behave in a way that leads to success of your department, division or subsidiary.

So, while you may not have asked for this public relations advice, I hope you will agree that people you deal with behave like everyone else – they act upon their perceptions of facts they hear about you and your operation. Leaving you little choice but to deal promptly and effectively with those perceptions by doing what is necessary to reach and move your key external audiences to action.

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Bob Kelly counsels, writes and speaks to managers about using the fundamental premise of public relations to achieve their operating objectives. He has been DPR, Pepsi-Cola Co.; AGM-PR, Texaco Inc.; VP-PR, Olin Corp.; VP-PR, Newport News Shipbuilding & Drydock Co.; director of communications, U.S. Department of the Interior, and deputy assistant press secretary, The White House. mailto:bobkelly@TNI.net Visit:http://www.prcommentary.com