Vikas,

If the "dietary purpose" is treatment (including evaluations and assessments
for food-intake, medication contraindications, etc.) the dietician would NOT
be defined under HIPAA as a "business associate".  However, if the "dietary
purpose" is related to say, a quality improvement activity (defined under
HIPAA as a "health care operation"), then the possibility exists for the
dietician to be defined as a "business associate".
 
I hope that this helps.
 
Your questions are always welcome.
 
Matt
 
Matthew Rosenblum
Chief Operations Officer
Privacy, Quality Management & Regulatory Affairs
http://www.CPIdirections.com

CPI Directions, Inc.
10 West 15th Street, Suite 1922
New York, NY 10011
 
(212) 675-6367
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-----Original Message-----
From: Vikas Budhiraja [mailto:[EMAIL PROTECTED] 
Sent: Tuesday, February 25, 2003 11:52 AM
To: WEDI SNIP Privacy Workgroup List
Subject: Are dieticians Business Associates?

A question about Dieticians. If a contract dietician reviews a patient's
medical charts for dietary purposes, is he/she considered a BA? Or would
this be considered part of treatment.

Thanks,
Vikas



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you wish to receive an official opinion, post your question to the WEDI SNIP Issues 
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