"If the billing company does all its transactions as Standard Transactions", then it 
would be considered a clearinghouse and therefore a CE rather than a BA; is this not 
correct?

And the CE is actually the one that is technically responsible in implementing the BA 
agreement, aren't they?

Just my thoughts!  ~Brenda




 The Billing Companies won't need to ensure any BAAs are in place unless someone out 
there acts on behalf of the Billing Company rather than on behalf of the Covered 
Entity (Provider) [CUSTOMER!]
> 
> Their Customers will need BAAs in place with the following:
> *   The Billing Company
> *   A Collection Agency, if used
> *   Any Transactions Clearinghouse (note: if the Billing Company does all its 
>transactions as Standard Transactions, a BAA is not required with a clearinghouse 
>acting only as a switcher -- just an ordinary contract to do business)
> 
> Neither the Billing Company nor their Customers need BAAs with any Health Plans 
>unless they doing a non-health-plan function.
> 
> 
> The opinions expressed here are my own and not necessarily the opinion of LCMH.
> 
> Douglas M. Webb
> Computer System Engineer
> Little Company of Mary Hospital & Health Care Centers
> [EMAIL PROTECTED]
> 
> "This electronic message may contain information that is confidential and/or legally 
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> 
> ----- Original Message ----- 
> From: <[EMAIL PROTECTED]>
> To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]>
> Sent: Tuesday, February 04, 2003 02:11 PM
> Subject: Business Associates Agreements
> 
> 
> > Hi, I'm helping some small Billing companies in my area
> > become HIPAA compliant and I'm not sure if they need a
> > Business Associates Agreement with the Insurance
> > carriers that they submit claims to.  Any information
> > would be greatly appreciated.  
> > 
> > Thank you,
> > 
> > M.Noren
> > 
> > ---
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> The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions 
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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/.   These listservs should not be used for 
commercial marketing purposes or discussion of specific vendor products and services.  
They also are not intended to be used as a forum for personal disagreements or 
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