PRIVACY: CLEARINGHOUSES ACTING AS BUSINESS ASSOCIATES

[Bard, Greg]

In the preamble to the Privacy Regulation, there is a discussion as to the applicability of the requirements in Section 164.500.  From the discussion, it appears that a healthcare clearinghouse, acting as a Business Associate, does not need to honor the requirements for individual requests for privacy protections.  This would be all the individual rights. However, it seems that the Business Associate contract must include provisions for access/copy, amendment, and accounting of disclosures.   Am I interpreting this correctly and can someone provide clarification?   Thanks!       Greg Bard NASCO HIPAA Privacy and Security Project Manager (W) 678.441.6059 (F)  678.441.6359 [EMAIL PROTECTED]     ______________________________________________________________________________________ CONFIDENTIALITY NOTICE The information in this message (and the documents attached to it, if any) is confidential and may be legally privileged. It is intended solely for the addressee. Access to this message by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken, or omitted to be taken in reliance on it is prohibited and may be unlawful. If you have received this message in error, please delete all electronic copies of this message (and the documents attached to it, if any), destroy any hard copies you may have created and notify me immediately. Thank you.           --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@mail-archive.com To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org