to me, there is no
distinction in privacy between BA and CE ... when the BA is "contracted" on
behalf of the covered entity. Once that happens, they are also responsible
for all the requirements of the privacy rule and the PHI that they handle within
their systems.
Ruth
Tucci-Kaufhold
HIPAA Systems Analyst
UNISYS Corporation
4050 Innslake Drive
Suite 202
Glen Allen,
VA 23060
(804)
346-1138
(804) 935-1647
(fax)
N246-1138
[EMAIL PROTECTED]
Ruth,
When you say they are now regulated by the
privacy and security, you mean as a business associate right?
Thanks for the clarification.
Jim
----- Original Message -----
Sent: Wednesday, October 16, 2002 5:16
PM
Subject: RE: TPA question
A rebiller is
definitely a Business Associate as stated in the definition ... "...
performs a function or activity regulated by this subchapter on behalf of a
covered entity, as defined by this section."
It appears that the
rebiller might be "out of a job" if they cannot at the very least accept an
837 claim that they are "rebilling" for their customer (covered
entity). If the provider has to transmit an 837 and the payer has to
receive an 837 ... what exactly is the rebiller going to
get?
And ... they would
now be regulated by the privacy/security rule as well.
Ruth
Tucci-Kaufhold
HIPAA Systems Analyst
UNISYS Corporation
4050 Innslake Drive
Suite 202
Glen
Allen, VA 23060
(804) 346-1138
(804) 935-1647 (fax)
N246-1138
[EMAIL PROTECTED]
Are
TPA's who reprice claims for insurance companies required to accept the
standard 837 per HIPAA guidelines?
Basically, we have a few third party
administrators who believe they are exempt - and in so, require and will
continue to require, additional data elements when claims are sent for
re-pricing AND they do not believe they would be regarded as Business
Associates.
Any
feedback?
Tamara
Havenhill-Jacobs
HIPAA Project
Lead
Exempla
Healthcare
303-837-6737
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