I agree as well, it would be considered a covered entity forever.  But, let's not 
forget, they would also be considered a covered entity if they use a business 
associate to send an electronic transaction.

>>> [EMAIL PROTECTED] 10/2/01 10:50:57 AM >>>


>>But for privacy purposes, is it still a
"covered entity"?  We note that, if a provider never sends an electronic
transaction, it never becomes a covered entity.  But if it sends just one,
did it touch the third rail, is it covered now forever?<<

My understanding is yes, once sent electronic it is covered in any and all
future forms.
Other opinions?

Bill




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