Please comments on these two situations:

   1. The request of non-BA public health plan (lets say Plan A) to the
State Plan, of eligibility information of the enrollees in the Medicaid
program constitutes a minimum necessary violation under HIPAA? 

   2. Can Plan A be in charge of the eligibility system of the State
Plan without been a BA?

Thanks ...

Jorge

 
Jorge Laguna
Oficial Principal de Privacidad y Seguridad
(Chief Privacy and Security Officer)
Departamento de Salud
Tel.: (787) 777-2702
Fax:: (787) 777-2710

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