Noel, I asked that question at the SNIP Conference in Chicago early last year and was told that if a healthcare provider does NOT electronically transmit any of the covered transactions, then they will not have to comply with the Privacy & Security Regulations.
However, a HC Provider will not be excluded from complying with the Privacy & Security rules by merely using a billing service/company to transmit electronic transmissions. Has anyone else heard anything different? Max Bumbalough HIPAA Consultant GovConnect, Inc. (800)565-4873 x230 [EMAIL PROTECTED] >From: Noel Chang <[EMAIL PROTECTED]> >To: [EMAIL PROTECTED] >Subject: Covered entities >Date: Mon, 18 Mar 2002 10:44:45 -0600 > >Has anyone seen any further clarification from DHHS on who must comply >with the Privacy Rule? > >The way I interpret the final rule published in December of 2000, and >the guidelines published in July of 2001, the only health care providers >that must comply are those who electronically conduct one or more of the >ten covered transactions. I have encountered a specialist who does not >accept any insurance, they are a cash only operation. As such they do >not file any claims or deal with eligibility, etc. By my reading they >would appear to not be a covered entity and therefore are not required >to comply with the Privacy Rule. > >I keep seeing information from various sources (not DHHS or OCR, >however) that make very broad statements such as "HIPAA applies to >everyone" or "there are no HIPPAA free records". I can understand what >they mean by these statements in certain context but I think they are a >little too broad and misleading. Does anyone else agree that a doctor's >office who is not electronically conducting a covered transaction is >therefore not a covered entity for the purposes of the Privacy Rule? If >you do not agree, can you cite where is the requirement that such an >office comply with the Privacy Rule? > >Thanks, > >Noel Chang > > >********************************************************************** >To be removed from this list, go to: >http://snip.wedi.org/unsubscribe.cfm?list=privacy >and enter your email address. _________________________________________________________________ Get your FREE download of MSN Explorer at http://explorer.msn.com/intl.asp. ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=privacy and enter your email address.
