akwallace
Jul 17 2003, 11:06 AM
When should the Business Associate Agreement be signed with a new insurnace vendor for a plan beginning 1/1/04? Does it need to be signed prior to 1/1/04, as PHI may be shared during open enrollment?
Steve72
Jul 17 2003, 11:26 AM
Insurance companies are not business associates of a fully insured plan.
If this is an insurance company serving as an ASO, a BAA should be signed before any PHI is transmitted.
akwallace
Jul 17 2003, 12:00 PM
This is a self insured CDHP, with Lumenos as the vendor.
kowen
Jul 22 2003, 07:55 AM
Steve72 is absolutely correct. The BAA must be in place before the plan can share any PHI.
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