We also have made the same interpretation.  However, we are unclear about how this 
applies to electronic exchanges that are part of standard transactions and code sets.  
How do you know when a standard transaction is being conducted by the self insured 
health plan or the employer sponsor of that health plan?  I am asking because the 
self-insured health plan is a covered entity, but not its employer.  (This 
differentiation is actually referenced in FAQs from DHHS.)

>>> Mary Michal <[EMAIL PROTECTED]> 03/19/02 08:00PM >>>
 The health plans of self-insured employers are indeed Covered Entities and
subject to Electronic Transactions and Privacy Rules.  We have analyzed the
Rules and developed compliance materials.

Mary Michal  

-----Original Message-----
From: McCall, Allen
To: '[EMAIL PROTECTED]' 
Sent: 3/19/02 10:53 AM
Subject: Employers impacted



Has anyone determined if/how self-insured employers are impacted by
HIPAA.  I am hearing that the health plan portion of the company must
comply with Rule 1.

Has anyone figured this out? 

Allen McCall    
Sierra Systems  
10900 NE 8th Street, Suite 400 
Bellevue, WA 98004-1455 
Telephone:  (425) 586-5438 
Mobile:  (425) 894-0790 
Fax:  (425) 586-5439 
[EMAIL PROTECTED] 
http://www.sierrasystems.com <http://www.sierrasystems.com>  


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