: Billing Services with
Contractors
Daniel,
1) Billing Services are Business Associates of
Providers. Because of what they do, if they work with standard
transactions, they may also be considered a Covered Entity Clearinghouse
(converting [highly] non-standard data to standard
Daniel,
1) Billing Services are Business Associates of
Providers. Because of what they do, if they work with standard
transactions, they may also be considered a Covered Entity Clearinghouse
(converting [highly] non-standard data to standard transactions, and vice
versa).
2) An entity that
Leslie -
So if my billing company did not consider itself a clearinghouse (thus a CE); and we
were only a BA, then anybody we subcontracted to would require us to have a BA as
well, (e.g. 'second tier business associates')? I have not seen/been told that
before. Please indicate where that
Daniel,
I
believe that your Billing Service would most likely be a BA,but check to
make sure you're not conducting standard transactions because that could make
you a Covered Entity...but that's a whole other issue.
I'm disturbed that your attorney is confused on this
issue. One of the
: RE: Billing Services with Contractors
Leslie -
So if my billing company did not consider itself a clearinghouse (thus a
CE); and we were only a BA, then anybody we subcontracted to would
require us to have a BA as well, (e.g. 'second tier business
associates')? I have not seen/been told
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
PROTECTED]
Cc: [EMAIL PROTECTED]
Subject: RE: Billing Services with Contractors
Leslie -
So if my billing company did not consider itself a clearinghouse (thus a
CE); and we were only a BA, then anybody we subcontracted to would
require us to have a BA as well, (e.g. 'second tier business
associates
