Lindsay,

I have read most of the comments regarding the questions you asked regarding
the covered entity responsibility for a provider, and when they are
responsible for adhering to privacy regulations.

I am sharing a section from the privacy final rule that may shed some light
on your question or add to the confusion, either way I hope the information
will be beneficial.

"In the final rule, the scope is extended to the protection of all
individually identifiable health information in any form, electronic or
non-electronic, that is held or transmitted by a covered entity.  This
includes individually identifiable health information in paper records that
has never been electronically stored or transmitted."

This section is from: Standards for Privacy of Individually Identifiable
Health Information , December 20, 2000,  Final Rule   page 117, 118.

Thank you for providing insight to the provider side, regarding compliance
issues.  I work more with health plans, but interested in how the provider
will be affected.

Have a nice day.  

-----Original Message-----
From: Askew, Lindsay W [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, October 02, 2001 3:57 PM
To: '[EMAIL PROTECTED]'
Subject: RE: Once covered, always covered?


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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