One of the recent trends is to send paper claims offshore (outside of the
US) for data entry.  This is often done by sending scanned files of paper
claims.  This practice may even increase in the future due to the "paper
backlash" some expect  from providers who were electronic submitters and who
decide to switch to paper due to HIPAA compliance expense or complications
and other issues.  

I am interested in hearing some viewpoints on how HIPAA Privacy will affect
this off shore keying practice.  It seems that since HIPAA is a US law only,
there will be no ability to enforce its' provisions outside of the US.
Therefore no foreign company can be held to task for not protecting PHI or
using it in a manner not allowed under HIPAA.  

I also have read of some off these off shore data entry companies (or their
employees) selling social security numbers (they dealt with credit card
data) to members of the Russian mafia who  used it in identify theft and who
knows what else.  

Does anyone know of a specific requirement in HIPAA or via other federal
rules that claims can not be keyed off shore?  For the lawyers in the
audience - any commentary would be appreciated.  Should a best practice be
not to allow keying of PHI off shore?

Jim Hazelrigs
[EMAIL PROTECTED]
4905 Waters Edge Drive, Raleigh, NC  27606
tel: 919 233 6820





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