Rachel, So if the bank translates to/from a HIPAA standard on its OWN behalf (i.e. for the benefit of the bank's internal system, rather than "on behalf of" the CE sending/receiving the message), then that would NOT make it a CH... right? Could the bank (also for its OWN convenience/benefit) translate the 835 into a proprietary format before sending it to the provider... without making itself a CH? This "on behalf of" attribute seems a little vague because something could be done to benefit either or both parties, but not actually be "required" by the payor or provider.
-Chris At 04:11 PM 4/24/02 -0500, Rachel Foerster wrote: >Now, if either bank was taking either non-standard or standard data and >reformatting it into either standard or non-standard data on behalf of their >customer, then that bank is acting in the role of a clearinghouse and >thereby becomes not only a covered entity under HIPAA, but also a business >associate of their customer, the covered entity, under HIPAA's privacy >regulation. Christopher J. Feahr, OD http://visiondatastandard.org [EMAIL PROTECTED] Cell/Pager: 707-529-2268
