The regulation says the fee may be "reasonable" and "cost based"
There is no way you can meet the test of these two requirements with a flat
fee
unless you plan to charge based on the cost of the smallest possible record
- then it does not seem worth doing.

cite 164.524(c)(4)

My opinion
BK

-----Original Message-----
From: Smith, Patricia [mailto:[EMAIL PROTECTED]]
Sent: Wednesday, February 19, 2003 3:41 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Fee for Access


We are a health plan. We are trying to determine what to charge for
‘Access’. We have decided we want have it be a flat fee regardless of how
long you have been with the plan. We generated reports from our current
system (without regard for our business associates) on a few members and
came up with documents that ranged from a ¼ inch to 3 inches of output
(combination of printouts from previously scanned documents and computer
generated reports).

We are no closer at determining a fee. We would really prefer a flat fee and
not a per page. Since we don’t have face to face contact, it’s easier on the
members and us if we set a flat fee.

What are other plans charging?

Thanks!
Pat Smith


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on this listserv therefore represent the views of the individual participants, and do 
not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If 
you wish to receive an official opinion, post your question to the WEDI SNIP Issues 
Database at http://snip.wedi.org/tracking/.   These listservs should not be used for 
commercial marketing purposes or discussion of specific vendor products and services.  
They also are not intended to be used as a forum for personal disagreements or 
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