----- Original Message -----
Sent: Wednesday, March 19, 2003 12:33
PM
Subject: Re: Billing Services with
Contractors
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
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----- Original Message -----
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.
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