Kathleen,
It is true that you are disclosing to a third party that is not required
to protect the information under HIPAA.  However, there are many
examples of this because HIPAA only governs covered entities and those
organizations acting on behalf of covered entities (BA), and it is
recognized that there are disclosures to entities that it cannot
regulate:

So, disclosures to a third party required by law - like mandatory
registries are allowed under HIPAA but the information is not protected
once the registry has it, disclosures by a provider to workers
compensation are the same way, as are some disclosures to financial
institutions (depending on whether they are acting as a BA or not), and
the disclosures below.  


Leah Hole-Curry
Fox Systems Inc.
602-708-1045

>>> "Kathleen Golovan" <[EMAIL PROTECTED]> 03/27/02 09:36 AM >>>
But is there an issue because you are sharing with a third party that is
not a Covered Entity and not a Business Associate in order to facilitate
"payment. 

For example, when I use a third party to do something that qualifies as
"healthcare operations" I must have a Business Associate Agreement with
them to protect the information when it leaves my control. What is
protecting the information when I send it to the property/casualty
insurer



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