We are a health plan and have opted not to delay executing our BAA due to the fact 
that we will still be responsible for providing members' access, accountings, etc.  
Without business associate agreements, we have no way to ensure that our business 
associates will provide us with the required information so that we can provide the 
members with the requested information.
>>> "Dee Warrington" <[EMAIL PROTECTED]> 09/19/02 11:54AM >>>
I just ended my employment with a payor who opted not to delay executing their 
business associate agreements.  The reason for not delaying had to do with the other 
privacy regulation, the Gramm-Leach-Bliley Act.  Many states adopted some or all of 
the GLBA privacy requirements which are already effective.  So..instead of having to 
send out a business associate agreement to comply with GLBA and then amend the 
requirement to comply with HIPAA...this plan chose to address both regs at one time.  
I am not sure what state you are in but you may want to see if they adopted any form 
of the GLBA.

Dee Warrington
Director, HIPAA & Regulatory Compliance
OAO Health Care Solutions, Inc.  

-----Original Message-----
From: Grimes, Colleen [mailto:[EMAIL PROTECTED]] 
Sent: Thursday, September 19, 2002 5:17 AM
To: [EMAIL PROTECTED] 
Subject: Business Associate Agreements


Hope someone can give me feedback regarding any MCO's plans on executing
business associate agreements.  With the year extension that was provided, I
was curious what payers timelines are for executing their BA agreements.
Has anyone executed their BA agreements or are MCO's delaying until next
year?  What would be your rationale for either delaying or executing had the
date had not been extended?

Thanks,

Colleen Grimes

Colleen Grimes
AVP, HIPAA Compliance
757-473-2737 X3115
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