I would like to receive opinions regarding the following:
Title 45, CFR �162.103 defines "Health plan" to include an individual or group plan "that provides, or pays the cost of, medical care...". "Health Plan A" is a major medical health plan that contracts Company B to provide specialized medical care (for example, vision or dental care) to Company A's enrollees. "Company B" provides that specialized medical care through its contracted providers and pays those providers for such services. To carry out its contract obligations, Company B needs to receive data identifying Health Plan A's enrollees.
Do you agree or disagree with the following? In either case, please explain why:
1. Company B falls within the definition of "Health plan" because it provides or pays the cost of medical care.
2. 45 CFR 162.1502 allows Health Plan A to send Company B the necessary data via an 834 transaction.
3. A data transmission from Health Plan A to Company B cannot be deemed a compliant 271 eligibility response absent a 270 eligibility inquiry.
Thank you in advance for any opinions that you would be willing to share.
Stuart Thompson
Vision Service Plan
Rancho Cordova CA
[*Please note: The above statements and questions are my own and do not necessarily represent the views of my employer].
