We often times have to disclose information for purposes of treatment to
orthotists, durable medical equipment providers.  Normally it would appear
that these folks are covered entities(since they bill the insurance for
their services electronically)  But one of the groups has less than 10
employees so they are exempt from covered entity(or some may file paper
claims to avoid covered entity status.)  What does that make our
relationship since HIPAA allows us to disclose PHI freely to other covered
entities for purposes of TPO?

Craig Moen
Director of Rehabiliation
HIPAA Privacy Official
THERAPY 2000



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