RE: Business contracts between CE

2003-02-24 Thread Matthew Rosenblum
Robin, It is my understanding that NO business associate agreement is needed between CEs that share PHI as long as both of those entities are acting in their respective roles as CEs (as opposed to BAs.) For example, when a provider hires a clearinghouse to translate non-standard

RE: BA contracts

2003-02-24 Thread Matthew Rosenblum
Robin, 1) The BAC would be in effect as long as the stated duration (in the BAC). 2) If the BA has no understanding of HIPAA, then, in all probability, a CE would be precluded from sharing PHI with that BA. 3) Usually, no BAC is needed for the purpose of sharing PHI for treatment

BA Agreement

2003-02-24 Thread Kristen Emerson
My agency is entering into a contract with a pharmacist to provide free brown bag checks for elderly citizens. These brown bag checks consist of an elderly citizen bringing all the prescription drugs that they are taking to the pharmacist and receiving counseling on medication management by the

ACE vs OHCA

2003-02-24 Thread PainClinicAssoc
Would someone please address the advantages or disadvantages of an ACE arrangement over an OHCA for 2 separate companies within a private practice? Thanks very much Vicki Saunders Pain Clinic Associates, PC Pain Clinic Associates, PC Confidentiality Notice: The information contained in this

Re: BA contracts

2003-02-24 Thread Doug Webb
Robyn, 1) The term of the BA contract is as long as it itself states. 2) Other than using another entity, I'm not sure. You are responsible for whatever PHI they leak, unless you have that contract in place makeing them responsible for their actons. 3) I think your list covers everything,