There is a position paper present in the Privacy Policies & Procedures whitepaper on Brokers and Agents. I agree with Bill - that Agent is either 1 - a Business Associate of the Health Plan subject to the rights and restrictions in his BA contract with me 2 - a Business Associate of the Employer/ERISA Plan subject to the same restrictions as that Employer 3 - none of the above and has no rights unless I have an Authorization or Personal Representative Form on file from the member.
-Beth Kranda Bill Bernath wrote: > Cathy, we've be wrestling with this for a bit. I wish it was as simple as it >sounds, but we see the agent falling into a couple of categories - one that works >directly for us, that is, a paid employee of BCBSNC. We'll assume that this agent >is representing our interests. The other category is agents that are not employees, >but instead are representing either the member or the group health plan. For either >category, but especially for the non-employees, we are leaning towards absolutely no >disclosure of PHI (without proper signed authorization on file, of course). So far, >we have not been able to come up with instances where an agent would 'need' PHI. If >someone in the group can make a case for it, I'd be glad to put it in our mix for >further consideration - thx- b > > Bill Bernath > Blue Cross Blue Shield of North Carolina > Privacy Office > (919) 765-7006 > [EMAIL PROTECTED] > > >>> <[EMAIL PROTECTED]> 03/26/02 08:05PM >>> > Does anyone in the WEDI SNIP Privacy Workgroup know the > industry's perspective and the Agents perspective on whether > Agents should have rights to PHI. I would really appreciate > your input on this. > > Thank you. > > Cathy Kiaha > Manager, Education and Communications > HIPAA PMO > > PHONE: (818) 234-3154 > FAX: (818) 234-3841 > E-MAIL: [EMAIL PROTECTED] > > ********************************************************************** > To be removed from this list, go to: >http://snip.wedi.org/unsubscribe.cfm?list=privacy > and enter your email address. > > ********************************************************************** > To be removed from this list, go to: >http://snip.wedi.org/unsubscribe.cfm?list=privacy > and enter your email address. ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=privacy and enter your email address.
