FYI -----Original Message----- From: Stanley Nachimson [mailto:[EMAIL PROTECTED]] Sent: Friday, June 07, 2002 11:30 AM To: Lisa LaMont Subject: Re: FW: TCS extension if you are a BA
There is no downside to filing for the extension. If it turns out you are not a clearinghouse, then you are not subject to the standards. Your declararation that you are a clearinghouse is not binding. Stanley Nachimson HIPAA Project Team, CMS 410-786-6153 >>> <[EMAIL PROTECTED]> 06/07/02 01:32PM >>> Mr. Nachimson, I have a question for you regarding the extension process. We are a national PPO and currently defined as a BA. However, we do conduct a lot of EDI and have come close to agreeing to some models that could redefine us as a CE under the definition of a clearinghouse. Would it be in our best interest to file for an extension even though we are a BA but may potentially become a CE due to a business agreement? The only downfall I would see is that we are declaring ourselves as a CE if we complete the extension model and may remain a BA. Then HHS would have it on record that we are a CE and we could potentially be liable for penalties. Your input is appreciated. Regards, Lisa La Mont -----Original Message----- From: David Frenkel [mailto:[EMAIL PROTECTED]] Sent: Friday, June 07, 2002 9:32 AM To: Lisa LaMont Subject: RE: TCS extension article Lisa, Several other organizations have asked similar questions and I have not seen a definitive answer (if there is one). You are definitely in a catch 22 on this issue. I would seriously doubt that it would cause any problems if you did the extension and decided against becoming a CE, if nothing else you could plead ignorance. I am sure there are many organizations filing the extension that don't need to just out of fear/ignorance. The reality is CMS has no funding to do anything with all the information they are getting from people filing extensions, this is why there is no review of the filings only an acknowledgement from CMS that it was received. You might try to send this question to the point guy at CMS who answers these types of questions. If you get an answer could you put it out on the listserv? Thanks. His name is Stanley Nachimson, [EMAIL PROTECTED] . Good luck. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Friday, June 07, 2002 9:05 AM To: [EMAIL PROTECTED] Subject: RE: TCS extension article Hi David, I have a question for you regarding the extension process. We are a national PPO and currently defined as a BA. However, we do conduct a lot of EDI and have come close to agreeing to some models that could redefine us as a CE under the definition of a clearinghouse. Would it be in our best interest to file for an extension even though we are a BA but may potentially become a CE due to a business agreement? The only downfall I would see is that we are declaring ourselves as a CE if we complete the extension model and may remain a BA. Then HHS would have it on record that we are a CE and we could potentially be liable for penalties. Your input is appreciated. Thank you, Lisa La Mont Beech Street Corporation -----Original Message----- From: David Frenkel [mailto:[EMAIL PROTECTED]] Sent: Thursday, June 06, 2002 2:07 PM To: [EMAIL PROTECTED] Subject: TCS extension article This is from todays AHA newsletter. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 6) HHS receives thousands of request to extend compliance deadline More than 13,000 companies and organizations are seeking an additional year to comply with a Department of Health and Human Services' rule on electronic data interchange, Elizabeth Holland of HHS' Centers for Medicare & Medicaid Service told a regulation compliance conference this week. Affected entities have until Oct. 15 to submit compliance plan or ask for an extension. The regulation is one of several mandated by the administrative simplification title of the 1996 Health Insurance Portability and Accountability Act. The administrative simplification rules are designed to cut costs by streamlining the administrative and financial transactions in the health care industry. CMS is encouraging health care organizations seeking an extension to file electronically. For electronic filers, the CMS Web site issues an automatic confirmation number to ensure the health care organization that its compliance plan has been received. More information is available at <http://cms.hhs.gov/hipaa/hipaa2/default.asp>. ************************************************************************ ************************************* Confidentiality Statement - This Email is confidential. The information is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. 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