Is an entity that is acting as a third-party administrator to a group health plan a covered entity?
No, providing services to or acting on behalf of a health plan does not transform a third-party administrator (TPA) into a covered entity. Generally, a TPA of a group health plan would be acting as a business associate of the group health plan. Brokers/consultants and brokerage agencies that act on behalf of CIGNA HealthCare are not considered part of that covered entity (CIGNA HealthCare); rather they are business associates of the covered entity.
