I am working with a small provider office (4-physician group) who are 
concerned about the need to create Business Associate Contracts or Chain of 
Trust Agreements with all of the insurance carriers they currently do, or 
potentially will, send a claim to. Is it necessary for the provider to have 
these contracts/agreements in addition to the agreements they have with 
their clearinghouse and/or billing company? Or, does the patient consent 
form (permitting disclosure for TPO) and an appropriate Business Associate 
contract with the clearinghouse exempt the provider from needing agreements 
with each individual carrier?

Thank you for your comments.
-Jonathan May

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