Daniel: Not all billing services are “business
associates” only. If your
billing service performs any “translations” of standard to
nonstandard data elements in connection with any of the standard transactions (e.g.,
if you receive any print images of non standard itemized bills your provider
clients have sent and key them into an 837 for re-billing or for billing to an
insurer you now have discovered) your billing service may meet the HIPAA
definition of a “clearinghouse” and thus you would be both a
business associate and a covered entity. If you have any vendors with whom you
use/exchange PHI on behalf of your provider clients, they would likely be
second tier business associates and yes you would need to have them execute BA
agreements with you at least as stringent as those you sign with your provider
clients. For example, if you
forward accounts from patients residing in other states to billing companies in
those states, you would need a BA agreement with the billing services to whom
you forward the accounts. ACA International, a non profit trade
association for, among others, billing and health care collection agencies has
extensive educational materials and an upcoming program applying HIPAA to
billing services and health care collection agencies. They have some upcoming educational
programs that may interest you and your counsel. Hope this helps. Leslie C. Bender ROI WebEd Company -----Original Message----- 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
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- Billing Services with Contractors Daniel E. McDonald
- Re: Billing Services with Contractors Doug Webb
- Re: Billing Services with Contractors Brenda K. Burton
- RE: Billing Services with Contractors Brenda K. Burton
- RE: Billing Services with Contractors Leslie C Bender
- RE: Billing Services with Contractors Jason Brege
- RE: Billing Services with Contractors Leslie C Bender
- RE: Billing Services with Contractors Beth . Kranda
- RE: Billing Services with Contractors Leslie C Bender
- RE: Billing Services with Contractors Brenda K. Burton
- Re: Billing Services with Contractors Anne Edwards