This came up in the testing conference call about TPA filing
extensions for their customers, it is from the CMS
FAQ.
Question:
Must every employer/plan sponsor independently submit an ASCA compliance plan
to obtain the extension? Our company is a third party administrator (TPA) for a
large number of employer-sponsored health plans under ERISA. They all have the
same implementation plan. May we file one plan as a TPA for all these plans?
Answer:
First, determine whether the plans are “small health plans” for
purposes of HIPAA. If they are, they already have a compliance date of October 16, 2003,
and are not eligible to file for a further extension. Many ERISA plans will
meet this definition. For those
plans that are not “small health plans”, the obligation to file a
compliance plan rests with the plan, not the TPA. The use of the same TPA does
not make two or more plans “related entities.” However, the TPA may
submit the ASCA compliance extension plans on behalf of the employer/sponsor.
Regards,
David Frenkel
Business Development
GEFEG USA
Global Leader in Ecommerce Tools
www.gefeg.com
425-260-5030
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