Business Associates are only required to be compliant as directed by their covered entities and to the extent they provide services that affect claims processing or deal with patient information. The compliance extension only applies to extensions for transaction and code set compliance so if you are not involved in transactions on behalf of the covered entity then you don't need an extension.
If you are providing transaction processing on behalf of a covered entity you may fall under the HIPAA definition of a clearinghouse which is a covered entity - not a business associate - be sure that the services are directly on behalf of the covered entity. As a business associate you don't have to file a compliance plan and are automatically extended if your covered entity has filed for an extension. If you need the extension for transaction services you provide for a covered entity then you need to get the covered entity to file a compliance plan. A business associate falls under the section in the compliance plan that details receiving services in support of transaction processing through a contractor or vendor. In all cases you need to accommodate a plan that assures HIPAA compliant transaction testing will commence April 16, 2003. This is generally interpreted to mean external testing with trading partners - that opinion is divided but considering the amount of testing that will need to be done to assure that trading partners can exchange HIPAA transactions without violating security, bringing down the systems on either end, corrupting the data, or interpreting the data and response incorrectly at each end this promises to be complex testing that will require at least from April to October to complete. Becky Reed -----Original Message----- From: Holman, Lisa A. [mailto:[EMAIL PROTECTED]] Sent: Wednesday, April 10, 2002 11:47 AM 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 ********************************************************************** 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.
