The plan is a normal plan funded through an insurance company like Humana or BCBS or United Healthcare. You are correct that the employer is not a covered entity and the agreement between the employer and leasing company do not currently treat the leasing company as a business associate, but...
Company A and Company B use an employee leasing company. For Company A, this employee leasing company may at times do nothing more than admin functions like issuing payroll and collecting the health insurance forms and payments from employees. For Company B, it may hires,...
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