Ruth,
As far as I know, there are no "before" versus "after" requirements
for HIPAA. What anybody does before has no bearing on the
requirements for compliance after. Thus the undefined word "delay", a
relative as opposed to absolute term, would have to be operationally
and case-by-case defined unless DHHS provides some additional official
explanatory materials (e.g., the future Enforcement regulation).
Can you cite any regulatory language that I may have missed? Thanks.
Dave Feinberg
Rensis Corporation
206-617-1717
[EMAIL PROTECTED]
----- Original Message -----
From: "Tucci-Kaufhold, Ruth A." <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>
Sent: Tuesday, February 12, 2002 1:14 PM
Subject: RE: 270/271 question
Does this discussion fit under that category of "an entity cannot
delay a
transaction?"
My interpretation of that is an entity cannot delay any of the
transactions
from "before HIPAA". So, if their reply "today" includes more
information
than yes/no ... isn't there some sort of "obligation" to at least
provide
what is being given today? If not, and they say yes/no and say if you
want
more ... isn't that "delaying" the transaction?
Maybe I'm too logical?
Ruth Tucci-Kaufhold
UNISYS Corporation
4050 Innslake Drive
Suite 202
Glen Allen, VA 23060
(804) 346-1138
(804) 935-1647 (fax)
N246-1138
[EMAIL PROTECTED]
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