Title: RE: BA v Trading Partner Agreements
I do
disagree with the below
The
TPA is a document used to establish EDI relationships. Those relationships
are not always between covered entities and are not always HIPAA
impacted.
A BAA
is a document between a CE and another company that
A Business Associate is someone who is performing a function on your behalf.
Many Business Associates are also trading partners because you send them a
file to carry out their duties.
A Trading Partner is an entity that you trade electronic data with. A
person can be a training partner and not a
Yes.
We do
this all the time. Internally we refer to these as subcontractor business
associates. We have a template called a c-BAA that we have sent to all out
subcontractors based on the provision in the BAA that requires us to pass
through the same requirements to any subcontractor.
The
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
I will only take 3)
164.502
(g)(1) requires that you treat a
Personal Representative as the individual i.e. must give
access
(g)(3)
requires that you treat a parent or guardian as a Personal Representative
The only
exceptions provided are described in (g)(3)
which seem to
be very
I will go out on a limb with an
unsubstantiated opinion because it is late
Only if the email also contained health
information or some indictor of health status - or -
If they could infer by the name or address
of the sender the health status of the recipient.
Would anyone out there agree
The citation Noel references below is true and can be found at 164.520 (c)
(3) (i)
An entity that maintains a web site ... must prominently post its notice on
the web site and make the notice available electronically through the web
site.
Thanks
BK
-Original Message-
From: Noel Chang
Title: RE: HIPAA privacy and telephone
Be
careful -
If you
say that an authorization is required, a y/n question will not fill the void
even if you track it.
If you
say that an authorization is required, it must be a HIPAA valid authorization
and there are a list of about 10 required
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