RE: Billing Services with Contractors

2003-03-19 Thread Jason Brege
ement from the BA to their own BA (a grand-BA!). References for this are: 45 CFR 164.504(e)(2)(ii)(D) and the model business associate agreement from the Preamble to the Final Rule. Thanks, Jason Brege Clinton A. Harkins, P.C. -Original Message-From: Daniel E. McDonald [mailto:[EMAIL

RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Jason Brege
of the patient's information. I believe this is the most straightforward way to go, but a Covered Entity should make sure the BA knows what types of disclosures to record, andthatmight be adaunting task with some BAs. Thanks, Jason Brege Clinton A. Harkins, P.C. -Original Message

RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Jason Brege
O purposes or otherwise, and then direct them to account for the non-TPO disclosures that would be accounted for if done directly by the Covered Entity. Thanks, Jason Brege Clinton A. Harkins, P.C. -Original Message-From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]Sent: Tuesday, Marc

RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Jason Brege
destroy. I think there are ways to justify this as Business Management, and I think your documentation of this decision would be key. I believe this is one reason why mostentities have just brought shredders or shredding companies onsite. Thanks, Jason Brege Clinton A. Harkins, P.C. ---