Are we all working from the same original facts? I read the original post to say that
one entity, a clearinghouse/billingagency/collection agency, was in the vortex of a
series of transactions and wanted to know if it needed BA agreements with providers
and payors that it found itself in the middle of -- not that there were 3 separate
companies. I apologize if I misinterpreted the back slashes in the post -- but I
didn't see the question as 3 separate entities asking if each fit the BA definition
and how..
Clearly a collection agency working for a payer needs no BA agreement with a provider
(that isn't its client) and the converse is true as well. Similarly a medical billing
company working for a provider is its BA -- but is not a payor's BA because it handles
an outsource of the provider's insurance billing and follow up functions (which equate
to "payment" in HIPAA).
To me the results change if you have one entity interchangeably being
clearinghouse/billing company/collection agency -- performing multiple tasks through
one corporate entity for the same group of provider and payor clients (e.g., it isn't
a hybrid, doesn't have separate corporate affiliates...)
Leslie Bender
---------- Original Message ----------------------------------
From: "Jamelle T. Magee" <[EMAIL PROTECTED]>
Date: Wed, 4 Sep 2002 09:59:30 -0400
>
>
>
>
>
>
>WE know that a BA relationship exists b/t provider and clearinghouse and
>no BA relationship exists b/t provider and health plan, per regs. I
>believe that like the provider, no BA relationship would exist b/t the
>clearinghouse and the health plan. However, I have been known to be
>conservative when designating BAs. What's your reasoning Leslie?
>
>
>
> Jamelle
>
>Jamelle T. Magee, JD
>
>Privacy Officer
>
>UNC Chapel Hill Student Health Service
>
>v. 919.843.2584
>
>
>
>
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