If you aren't a covered entity (even if you treat yourself as one) - why would you need to apply for an extension? You're not covered therefore you aren't "required" to adhere to the regulations (although you may be adhering to the regs for business reasons) so what would you be asking for an extension on? I believe you can take as long as makes sense for your business to become compliant. I wouldn't add confusion to HHS's lack of a process for collecting these extensions by submitting an extension if you are not a covered entity (they'd probably accept the extension just because the process is not geared to do otherwise).
Kris Owens
Senior IS Project Manager - HIPAA Project
505.923.8108
[EMAIL PROTECTED]
"You don't know what you can get away with until you try" General Colin
Powell
-----Original Message-----
From: Holman, Lisa A. [mailto:[EMAIL PROTECTED]]
Sent: Wednesday, April 10, 2002 12:47 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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