My understanding is that a provider has the option relative to transactions
and code sets (TCS).  If it chooses to transact a covered standard
electronically it must adhere to the standards AND at that point they are
also on the hook for the privacy regulations as well. Subsequent to that
activity they can choose to go paper, thus non-standard. However, they are
still on the hook for privacy.

-----Original Message-----
From: William Lambrukos [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, October 02, 2001 11:51 AM
To: [EMAIL PROTECTED]
Subject: Re: Once covered, always covered?




>>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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