Would you not have to have a "Chain of Trust" relationship, and a Trust Partner Agreement with the Bank in question for all importation exchange? I think so. Without it, you are liable. So the simple answer is, the bank would have to be HIPAA compliant for all areas and systems that receive and use that identified information. Sounds like a new business opportunity for a smart bank! HIPAA Compliant Banking Services!!! Any Bank VP's listening out there? Anyone own bank stock who wants to write a letter to your bank CEO?
Regards, Dr. Tim McGuinness, Ph.D. Sr. Compliance Specialist & Solutions Architect Certified HIPAA Chief Privacy Officer DynTek Inc. www.dyntek.com -----Original Message----- From: Bill Chessman [mailto:[EMAIL PROTECTED]] Sent: Monday, April 29, 2002 1:31 PM To: '[EMAIL PROTECTED]' Subject: RE: questions on the appropriate way to reply when there are errors in a transaction request This may not be the right place to ask this question (and it might not even be reasonable or valid), but since the thread is running here, I might as well throw it out: If an 835 contains patient information (even the patient name) is sent to an organization not required to be HIPAA compliant, isn't it a violation of the patient's privacy rules? The bank may not use the information, but since it's in the transaction, it is visible to a (theoretically) unauthorized party. Best regards, Bill Chessman Peregrine Systems, Inc.
