tci ED Coding & Reimbursement Alert - 2019 Issue 3

Reader Question: What Happens to HIPAA When Information Spans Borders?

Question: Our practice uses a small cloud services provider (CSP) based in Canada to store information. Does HIPAA still apply to our business arrangement since the vendor is outside the U.S.? SuperCoder Subscriber Answer: Yes, HIPAA regulations still apply to this relationship. All of the rules about electronic protected health information (ePHI), including the need for business associate agreements (BAAs), are still in effect even when the partnering vendor is not based in the U.S. Expert opinion: “Be aware that HHS Office for Civil Rights [OCR] warns of increased risk to ePHI processed or stored outside...

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