It seems to me that an extension request from a BA would be unnecessary. As I understand things, a BA's obligations under HIPAA arise solely as a result of the BA's relationship with the covered entity. The BA will (in 10/02 or 10/03) have a duty to comply with HIPAA because the covered entity with which the BA is linked will have that duty. If the covered entity requests and receives an extension, and therefore has no obligation to comply with HIPAA until the expiration of the extension period, doesn't the question of the BA's compliance become essentially a non-issue for that period?
I assume the same would be true for entities that are "volunteering" to comply with HIPAA across the board despite the fact that such entities are, by definition, BA's as opposed to covered entities. >>> [EMAIL PROTECTED] 04/10/02 01:46PM >>> 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 ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request. =====================================================The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. Posting of advertisements or other commercial use of this listserv is specifically prohibited. ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request. ====================================================== The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. Posting of advertisements or other commercial use of this listserv is specifically prohibited.
