Monday, June 25, 2012

Three simple steps to make an EIN for Technical Consulting

Go to this website: https://www.federal-ein-application.com and follow these steps

Three simple steps to make an EIN
Step 1) Click the top button "Sole Proprietor or Individual"
Step 2) Fill in your information (name, ssn, business name, where you live) & click next
Step 3) Fill in information on why you need an EIN and what you do
Reason: "Started New Business/Personal Use"
Primary Activity: Other
Product/Services Offered: Information Technology Consulting
Date Business Started: Today's Date

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A couple common questions about being a Corp-Corp

What is the big difference between being a W2 and a 1099 (aka Corp-Corp)?
You get money quicker as an employee.  As a "corp" you only get paid after you invoice (typically it take 60 days until you receive your 1st check).  As an employee you get your 1st check two weeks after you start.  


What things do I need to do as a "Company" instead of as an "Employee"?
In a W-2 you receive a salary, but in a Corp-Corp contract you receive payment.  Even though all money is green, getting money as a "payment" is different in 3 ways.
  1. Payment Terms
  2. Invoicing
  3. Quarterly taxes to the State and Federal Government

What are "Payment Terms"?
This is the part of the contract that define when you can invoice and how long you have to wait for your invoice to be paid.  Usually the payment terms are "Net 30 - Invoice Monthly".  This means you invoice your customer at the end of the month and the customer has 30 days to pay the invoice.  

How do I do invoicing?
USE ZOHO!  Your customer will tell you what they want to see in their invoice.  Cloud-based service (like zoho) can make invoicing a simple task and will save you hours with your accountant.  For tax purposes, I highly recommend having a customer's EIN in the invoice.

What does making an EIN do?  Does this have any Legal Implication?
The EIN is an identification number that you can use instead of your SSN.  Your legal/tax status has not changes because you have an EIN.  You just have another way of identifying yourself on: Taxes, Employment Contracts, Articles of Organization (for making an LLC), ets.


If EIN doesn't make me an LLC, why do I need it to do corp-corp contracts?
No, you are still just you... but this EIN let's you do the following
  1. Contract with vendors that require an EIN for their "Corp to Corp" contracts
  2. Fill out the one-pager "Articles of Organization" to become an LLC in your state

Thursday, June 7, 2012

Can Patient Discovery be practical for 42 CFR Part II Programs?

Does patient consent for a substance abuse provider to disclose their identity to another provider on a Health Information Exchange (HIE) also authorize subsequent disclosures to other providers on that HIE within 200 Miles?


I recently re-read the 42 Code of Federal Regulations (CFR) Part II for the purposes of building a Health Information Exchange (HIE) rules engine.  I found a section of this regulation that has particular relevance to a maintenance treatment program HIE seeking to conduct a "Patient Discovery".

Section 2.34 and the Central Registry exception for maintenance treatment programs
A substance abuse program that has received patient consent to disclose their identity to the central registry and thereby any/all programs associated with that central registry provided that the following conditions are met.
  1. Geography: The programs are within 200 miles of each other
    (programs in different states must also be within 125 miles of the central repository)
  2. Purpose: The purpose of the request and disclosure is to avoid patient enrollment in more than one maintenance treatment program (such as a narcotic dispensing program to treat morphine-like drugs)
  3. Event:
    • Patient Acceptance into treatment
    • Type/Dosage of Drug changed
    • Treatment of patient is interrupted, resumed, or terminated
  4. Patient consent: For HIE Repository to disclose identity    
  5. Patient Information limited to:
    • Patient Identifying Information
    • Medication 
    • "Relevant Dates"
Bottom Line:  Traditional "Patient Discovery" of substance abuse patients can be practical on HIEs with a 200 mile radius of providers.

References: