May Health Plan Business Associates Disclose PHI Directly to Other Business Associates of the Same Plan?
ThomsonReuters
JANUARY 20, 2022
QUESTION: We are a TPA that administers claims for many self-insured group health plans. We have a business associate contract with each plan. Sometimes, a plan instructs us to send claims information, which includes protected health information (PHI), to another business associate of the plan, such as a claims auditor or a medical reviewer. Can we do this if we do not have a contractual relationship with the other business associate?
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