Remember, if they sub-contract the transaction work, they are STILL a covered entity. Based upon what was described, I would believe the clinic to be a covered component of a hybrid entity.
Tim McGuinness, Ph.D. Consulting Specialist in Regulatory Privacy, Security, and Application Compliance (HIPAA/ASCA/FDA/CMS-HCFA/ICH/ADA 508c), [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> President, HIPAA Help Now [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> www.hipaahelpnow.com <http://www.hipaahelpnow.com/> Executive Co-Chairman for Privacy, HIPAA Conformance Certification Organization (HCCO) www.hipaacertification.org <http://www.hipaacertification.org> __________________________________________________________________ Phone: 727-787-3901 Cell: 305-753-4149 Fax: 240-525-1149 Instant Messengers: ICQ# 22396626 - MSN IM: [EMAIL PROTECTED] - Yahoo IM timmcguinness - AOL IM: mcguinnesstim __________________________________________________________________ =========================================================================== IMPORTANT NOTICE: This communication, including any attachment, contains information that may be confidential or privileged, and is intended solely for the entity or individual to whom it is addressed. If you are not the intended recipient, please notify the sender at once, and you should delete this message and are hereby notified that any disclosure, copying, or distribution of this message is strictly prohibited. Nothing in this email, including any attachment, is intended to be a legally binding signature. -----Original Message----- From: Jensen, Christine [mailto:[EMAIL PROTECTED]] Sent: Thursday, September 19, 2002 7:16 PM To: [EMAIL PROTECTED]; [EMAIL PROTECTED] Subject: RE: covered entity Rich, The definition of covered entity pertinent to a provider is whether they conduct any of the HIPAA defined transactions electronically; claims, payment, authorization, eligibility, claim status. Whether or not they fax information is not relevant to determining CE status. You say they do no outside billing, how do they get paid for service? -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Wednesday, September 18, 2002 12:58 PM To: [EMAIL PROTECTED] Subject: covered entity I am not sure if this is the correct forum for this question as most of the stuff I read in this list serve is highly technical jargon on the inner workings of computers. Nevertheless, maybe some kind soul can lend me their expertise or at least direct me to a good, SUCCINCT resource. So, here goes. Would a Student health service that has 4 employees, does no outside billing, does not normally fax any health care information (although they may receive faxed information- for example, a mother sending the immunization records of the student to the student health service) be considered a covered entity and thus be mandated to follow HIPAA? The reason I said "does not normally fax health information" is that they normally do not fax information but there may be rare instances where such protected health care information is faxed to a physician's office. If the determination of whether or not they were a covered entity hinged on the these faxes or not, then they would stop all outgoing faxes simply to avoid the overwhelming bureaucracy HIPAA brings. Thanks for any insight any of you can provide on this issue. Rich Dubuque, IA ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=privacy and enter your email address. The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. Posting of advertisements or other commercial use of this listserv is specifically prohibited. ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=ivacy and enter your email address. The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. Posting of advertisements or other commercial use of this listserv is specifically prohibited.
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