On Feb. 4, 2015, Anthem announced a data breach involving the personal information of more than 80 million individuals resulting from what it characterized as a sophisticated, targeted cyber-attack. Group health plans may be affected because Anthem: (1) provides insured health benefits; (2) administers health benefits for a self-insured plan; or (3) administers out of area/network claims.

Employers, as plan sponsors on behalf of their group health plans, need to identify how the Anthem breach may affect them, if at all, and get their arms around what they need to do in response. The following is practical guidance on what employers need to know and do now and in the coming weeks to comply with their legal obligations.

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