My feeling is that a self-funded group is the covered entity and the administrator is not. Since they are the ones who could go to jail, we are going to ask them to tell us what to do. I don't think ownership by a carrier matters, since the financial arrangement with the group (e.g. the self-funded agreement) defines who has what role. Ken Fody Independence Blue Cross
-----Original Message----- From: Jim Moores [mailto:[EMAIL PROTECTED]] Sent: Thursday, May 30, 2002 3:09 PM To: [EMAIL PROTECTED]; [EMAIL PROTECTED]; [EMAIL PROTECTED] Cc: John Frohlich; John Simon; Kathleen Golovan Subject: Questions on Group Health Plan certification: HI All.... Questions on Group Health Plan certification: Does a TPA who is providing administrative services for a Group Health Plan (GHP) need to obtain certification from the GHP that the GHP has amended its plan documents before releasing PHI to the GHP? OR is the TPA simply a Business Associate with no obligations to do so? Assume that the TPA is a wholly owned subsidiary of a Health Plan (Insurer). does the analysis change? Again, given all the conditions above, if the parent (insurance) company provides Stop Loss for the GHP where the TPA is processing claims, does the parent (insurance) company have to get Health Plan Certification from the GHP? does the TPA have any obligations under this scenario? Any input would be helpful...... Jim Moores - HIPAA Team Leader - Privacy Antares Management Solutions 23700 Commerce Park Road Beachwood, Ohio 44122-5832 [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> Phone: (216)292-1605 Fax: (216)292-1619 ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=privacy and enter your email address. ---------------------------------------------------------------------------- -- CONFIDENTIALITY NOTICE: This message is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that you are strictly prohibited from printing, storing, disseminating, distributing or copying this communication. If you have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Thank You, Antares Management Solutions. ============================================================================ == CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute and delete the original message. Please notify the sender by E-Mail at the address shown. Thank you for your compliance. ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=privacy and enter your email address.
