First, thanks to all that have responded to my posts. It is difficult to thank each responder individual, but your comments are greatly appreciated
Next, we are getting some conflicting thoughts/opinions on contract agencies and independent contractors. We utilize both of these entities to see patients for us. We then bill the insurance company. The contractors send us invoices for their services. So the only thing they do is see patients on our behalf(much like our own employees) I currently hold that we would train these people as extensions of our workforce and not need a business associate agreement Some of our staff went to a HIPAA conference yesterday. The presenter stated that (Paraphrased) "if that entity does not need to be HIPAA compliant, and the only reason they need to be compliant is because they are doing something on your behalf, they would be business associates" Without us supplying them with patients they would not need to be compliant because they do not bill electronically, nor would they need, or create PHI as a function of their job. Finally speaking to both of the contract agencies, it is clear that they do not believe they are covered entities and are looking to our HIPAA policies and procedures to educate their staff to become compliant with HIPAA. This is a bit of a quandry. My personal opinion is that these folks would be true extensions of our workforce and we should educate them as such and not need a business associate agreement Comments? Confidential Information This email message is intended only for the person or entity to which it is addressed. Unless otherwise indicated or obvious by the nature of this transmittal, the information contained in this email message is privileged and confidential, intended for the use of the intended recipient (or the employee or agent responsible to deliver to the intended recipient), you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message THERAPY 2000 1881 Sylvan Avenue Suite 210 Dallas, Tx 75208 --- 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: [EMAIL PROTECTED] 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
