I would think that any doctor working in a hospital will be subject
to the privacy rules...  
So e-mail will be subject to the privacy rules....
And after a long discussion here, apparently a fax IS NOT an electronic
transmission as specifically defined in the HIPAA rules....

But I think in any case they are at the minimum Business Associates...
Or if employees, they are part of the Covered Entity..

UNLESS they do all of their billing on paper!!  All of this only applies
if you use EDI....  But normal privacy rules that are not specified in the
HIPAA rules will apply then...  Whether they be more or less stringent...

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]
Sent: Monday, April 29, 2002 3:33 PM
To: [EMAIL PROTECTED]; [EMAIL PROTECTED]
Subject: RE: filing instructions


What if the physicians transmit claim or PHI related information via email?
Such as providing follow up clarification outside of the primary covered
entity's system?  They may individually use email to receive a request, then
provide additional info via a web-interface?  What about them faxing
documents directly from their private office or residence?  Might they then
be considered individual covered entities?

Regards,

Dr. Tim McGuinness, Ph.D.
Sr. Compliance Specialist & Solutions Architect
Certified HIPAA Chief Privacy Officer
DynTek Inc.
www.dyntek.com

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]
Sent: Monday, April 29, 2002 2:01 PM
To: [EMAIL PROTECTED]
Subject: filing instructions


I am a new member of this listserv, so please excuse me if you've already
addressed this topic in your conversations.

While attending the Fourth HIPAA Summit in Washington DC,  I posed a
question about requirements for including all physician codes on the
extension form.  I work in a hospital with 600+ practicing physicians and
was concerned about reporting each of their numbers on the form.  I was
told that individually these physicians would not be considered covered
entities since they do not transmit electronic transactions themselves, but
through the hospital's automated applications.  Therefore, only the
hospital's code would be needed on the extension form.  Would you agree
with this advice?

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