Todd -
A Covered entity is defined in the regs at 160.102 as a health plan;
health care clearinghouse; or a health care provider who transmits any
health information in electronic form in connection with a transaction
covered by this subchapter (ie transactions).

An "entity" is not defined in the regulations.  However, several places
in the official comments suggest that "entity" is synonomous with legal
entity so that for instance: a state agency is the legal entity
responsible for an impacted program's compliance or the corporate entity
is responsible to ensure a given line of business or component complies.

With reference to 162.925, the means that a health plan is required to
accept transactions not only from "covered entities" such as other plans
or providers, but also any other entity which may not be covered - like
a sponsor.  See comments at page 50317 of reg.  "In general, if a
covered entity conducts, using electronic media, a transaction adopted
under this part with another covered entity (or within the same covered
entity), it must conduct the transaction as a standard.  If any entity
(covered or not) requests a health plan to conduct a transaction as a
standard transaction, the health plan must comply."

Leah Hole-Curry
Fox Systems, Inc.
702-608-1045


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