Re: Billing Services with Contractors

[Doug Webb]

Daniel, 1) Billing Services are Business Associates of Providers.  Because of what they do, if they work with standard transactions, they may also be considered a Covered Entity Clearinghouse (converting [highly] non-standard data to standard transactions, and vice versa).   2) An entity that performs services on your behalf that involve PHI is your BA, and there should be a BA contract between you and that entity.  An entity that performs services on behalf of your provider customers is the BA of the provider, and technically there should be a BA contract between your customers and the contractor.  I believe that if you have a BA contract with the contractor, that establishes a chain of trust that will meet the contract requirements. (check this one out -- my eyes glazed over).   The opinions expressed here are my own and not necessarily the opinion of LCMH.   Douglas M. Webb Computer System Engineer Little Company of Mary Hospital & Health Care Centers [EMAIL PROTECTED]   "This electronic message may contain information that is confidential and/or legally privileged. It is intended only for the use of the individual(s) and entity(s)  named as recipients in the message. If you are not an intended recipient of the message, please notify the sender immediately,  delete the material from any computer, do not deliver, distribute, or copy this message, and do not disclose its contents or take action in reliance on the information it contains. Thank you."     ----- Original Message ----- From: Daniel E. McDonald To: WEDI SNIP Privacy Workgroup List Sent: Wednesday, March 19, 2003 11:58 AM Subject: Billing Services with Contractors I wanted to get input regarding Billing Services that use contractors to perform certain services.  My understanding is the Billing Service is considered a Business Associate and not a covered entity.  If that is true, would the contractors working for a billing service be Business Associates of a Business Associate and would they sign a similair BA agreement as the billing service did but between them and the billing service?? I look forward to everyone�s intepretation as even our attorney is a bit confused.     This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me immediately at 1-800-500-0175 ext 114 and permanently delete the original and any copy of any e-mail and printout thereof.     --- 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 --- 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