The relationship is not a business associate relationship.  The
insurance carriers are not performing any services on behalf of the
health care providers.  As a TPA for health plans, we do not intend to
sign BA agreements with providers, because we are not providing services
for these providers.   The consent and BA agreement with your biller or
clearinghouse should cover this. 

>>> "Jonathan May" <[EMAIL PROTECTED]> 02/08/02 03:01PM >>>
I am working with a small provider office (4-physician group) who are 
concerned about the need to create Business Associate Contracts or
Chain of 
Trust Agreements with all of the insurance carriers they currently do,
or 
potentially will, send a claim to. Is it necessary for the provider to
have 
these contracts/agreements in addition to the agreements they have with

their clearinghouse and/or billing company? Or, does the patient
consent 
form (permitting disclosure for TPO) and an appropriate Business
Associate 
contract with the clearinghouse exempt the provider from needing
agreements 
with each individual carrier?

Thank you for your comments.
-Jonathan May

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