ED Coding & Reimbursement Alert - 2017 Issue 8
HIPAA: Control BAA Breach Problems With 3 Tips
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Article Overview
This article is a practical HIPAA compliance discussion for healthcare practices, especially those working with outside vendors and service providers. It focuses on how to determine when a vendor is a business associate, why written agreements matter, and how confidentiality contracts may be used for certain third parties that do not handle protected health information. The piece is aimed at practice managers, compliance staff, and providers who want a general framework for reducing breach-related exposure without relying on the full premium article.
Why This Topic Matters
Business associate relationships can affect HIPAA liability, breach response, and contractual protections. Understanding the broad categories of outside parties that may require formal agreements helps practices manage vendor risk and maintain compliance.
Article Sections
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Step 1: Decide Who Constitutes a Business Associate
Introduces the first compliance step for evaluating outside parties and the kinds of services that may bring a vendor into scope for HIPAA-related oversight.
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Step 2: Execute BAAs
Covers the general need for written agreements once an entity is identified as a business associate and discusses the role of subcontractors and oversight considerations.
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Step 3: Enact ‘Cleaners’’ Confidentiality Contracts
Describes an alternative contract approach for certain third parties that do not handle protected health information and discusses the general purpose of confidentiality protections.
What You Will Learn
- How healthcare practices can broadly evaluate vendor relationships for HIPAA risk
- Why written agreements are important in managing outside-party privacy and security exposure
- When a confidentiality contract may be discussed as an alternative to a business associate agreement
- What general compliance concerns arise when subcontractors are involved
- How breach-related risk can extend beyond the covered entity itself
Who Should Read This
- Physician practices
- Surgery practices
- Practice managers
- Compliance officers
- Healthcare administrators
- Billing and operations staff
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