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 --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions 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 unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions 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 unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@mail-archive.com To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org