RE: Billing Services with Contractors

[Beth . Kranda]

Yes. We do this all the time.  Internally we refer to these as subcontractor business associates.  We have a template called a c-BAA that we have sent to all out subcontractors based on the provision in the BAA that requires us to pass through the same requirements to any subcontractor.   The whereasses go something like this   Whereas HIPAA requires a covered entity to... Whereas I am a BA of a covered entity... Whereas Contractor provides services to me through which it may have access to PHI of covered entity... Whereas we both desire...   I can't send you the whole agreement, but the rest of the cBAA reads much the same as our BAA.     -----Original Message----- From: Daniel E. McDonald [mailto:[EMAIL PROTECTED] Sent: Wednesday, March 19, 2003 12:59 PM To: WEDI SNIP Privacy Workgroup List 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