Welcome to the wonderful world of confusion!  Your understanding that a billing 
service is not considered a covered entity MAY be incorrect.  As a billing company, we 
have struggled with the clearinghouse 'definition'.  

If you are not considering yourselves a covered entity, as a business associate, you 
must take precautions and assure that PHI remains secure with your 
agents/subcontractors.  You may sign a confidentiality agreement with them and get 
their confirmation that you have explained your policies and procedures to them.   
Brenda




 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.
> 
>  
> 
>  
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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.

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