The extension is required for covered entities, as they are the ones that must meet 
the compliance deadlines.  If a business associate is a covered entity in its own 
right (for example, a health plan which is serving as an administratro of another 
health plan) it needs to file an extension as the covered entity, but not as the 
business associate.

Stanley Nachimson
Office of Information Services, CMS
410-786-6153

>>> [EMAIL PROTECTED] 04/10/02 02:46PM >>>
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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