Is the audit being done at your request or are you required to submit to the audit by the state?
If you are initiating the audit then I'd say you should have a BA agreement. If the audit is being imposed on you by the state then I'd say no BA is required. If the billing infomation you submit to the schools/nursing homes/welfare departments are for services you delivered to them, I don't see why a BA agreement would be necessary. You are making a disclosure to obtain payment. Such disclosures are specifically permitted, even if the disclosure is to the financially responsible party who is not the same person as the subject of the PHI. BA agreements are only necessary when you have a third party performing a covered function on your behalf. Noel Chang -- Open WebMail Project (http://openwebmail.org) ---------- Original Message ----------- From: "Teri Baskett" <[EMAIL PROTECTED]> To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]> Sent: Tue, 4 Feb 2003 17:42:31 -0500 Subject: BA Agreement Questions > I've met with my CFO and our Purchasing Mgr and we've figured out > most of our vendor list. But we had a couple of questions I hoped > someone could help with: > > 1. What do we do about auditors that come on-site to review records > for payment/compliance. If i read this right, if the auditor is a > govt agency (Medicaid or Medicare) then we don't need an agreement. > But our state contracts with another company to audit our state > contract funds. Do we have to have the BA with that company for that? > > 2. We have service contract agreements with several schools/nursing > homes/welfare depts. In addition to the treatment piece, we also > (of course) submit bills that include patient identifiers (name, SSN, > address). Do we need BA's for those relationships? > > Teri Baskett > Information Officer > LifeSpring Mental Health Services > > --- > 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 > unprofessional communication at any time. > > You are currently subscribed to wedi-privacy as: > [EMAIL PROTECTED] To unsubscribe from this list, go to the > Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a > blank email to [EMAIL PROTECTED] If you > need to unsubscribe but your current email address is not the same > as the address subscribed to the list, please use the > Subscribe/Unsubscribe form at http://subscribe.wedi.org ------- End of Original Message ------- --- 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 unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@mail-archive.com To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
