HI All....
Questions on Group Health Plan certification:
Does a TPA who is providing administrative services for a Group Health Plan
(GHP) need to obtain certification from the GHP that the GHP has amended its
plan documents before releasing PHI to the GHP? OR is the TPA simply a
Business Associate with no obligations to do so?
Assume that the TPA is a wholly owned subsidiary of a Health Plan (Insurer). does the analysis change? Again, given all the conditions above, if the parent (insurance) company
provides Stop Loss for the GHP where the TPA is processing claims, does the
parent (insurance) company have to get Health Plan Certification from the GHP?
does the TPA have any obligations under this scenario?
Any input would be helpful......
Jim Moores - HIPAA Team Leader - Privacy
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