We have several clients who are business associates of covered entities and
who have been told by their CEs that as BAs they must file for an extension
if the CEs are filing for an extension. We've just begun to look at the
question and will be interested in seeing the responses to your question.

William H. Roach, Jr.
Gardner, Carton & Douglas



-----Original Message-----
From: Holman, Lisa A. [mailto:[EMAIL PROTECTED]]
Sent: Wednesday, April 10, 2002 1:47 PM
To: Transactions (E-mail)
Subject: compliance extension for business associates


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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 04/10/02 
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