Tim,
 
I have been involved in a couple of examinations of this issue, and we sent a related query to HHS in an attempt to settle it.  That was over a year ago, and we still haven't gotten a response.  I was in a WEDI SNIP Business Issues Subworkgroup conference call last December 4, and Stanley Nachimson of HHS was a participant.  I took advantage of this opportunity to ask Stanley whether or not they were still looking at this submitted question.  He indicated that they were, indeed, working on it, but that they didn't have a final answer yet.  No estimate was given regarding when an actual answer will be available.
 
 - Zon Owen -
(808)597-8493
 
PS:  Incidentally, at least one organization has indicated that it performs automated COB between the Flex Plan Administrator, and a[nother?] health plan.  Thus, both the 834 and the 837 could be affected, along with privacy and security issues.
 
----- Original Message -----
 
Sent: Wednesday, September 04, 2002 10:57 AM
Subject: Flexible Spending Accounts and HIPA-AS

I can't find any references to flexible spending accounts (FSAs) or health
reimbursement accounts (HSAs) in HIPAA rules.  Any thoughts on whether those
activities are subject to HIPAA-AS rules and regulations?

Thanks
Tim Rearick, PMP
HIPAA-AS Project Team
Blue Cross and Blue Shield of Florida
> *   904-905-3129
> *     904-565-6097
*[EMAIL PROTECTED]

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