Is there verbiage anywhere that addresses whether a business associate, treating 
themselves as a covered entity, is eligible to file for transaction compliance 
extension?  Everything I've been reading about the exention seems to apply exclusively 
to covered entities only.  I guess my main questions are, would HHS even accept an 
extension plan from a business associate and has anyone else run into this particular 
scenario?

Thanks,


Lisa Holman
Haverstick Consulting
952.656.3733 




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