Due Diligence--HIPAA PHI

[Guest Michelle P]

Hi. Company A is currently leasing employees to Company B. Company B is anticipating hiring most or all of the leased employees. Can you tell me at what point Company A can share employee data (including HIPAA PHI) with Company B? Company B needs the PHI in order to negotiate a contract with a TPA for what will be its self-funded group health care plan. It needs to have the group health plan ready to go on the date the employees are hired.