no
Thanks,
Peg McCauley
HIPAA  Program Office
Phone:  309-765-0655
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        -----Original Message-----
        From:   Max Bumbalough [SMTP:[EMAIL PROTECTED]]
        Sent:   Monday, March 18, 2002 11:16 AM
        To:     [EMAIL PROTECTED]; [EMAIL PROTECTED]
        Subject:        Re: Covered entities

        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
        >
        >
        
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