tci Part B Insider - 2014 Issue 17

Spruce Up Your BAAs: Do your 'pre-existing' BAAs need an update?

Now’s the time to give your BAAs a spring cleaning. The Health Information Technology for Economic and Clinical Health (HITECH) Act requires you to update and revise your BAAs to ensure they’re in compliance with the HIPAA Omnibus Final Rule by September. The HITECH Act mandates that you negotiate and implement amendments to all pre-existing BAAs — those entered into prior to Jan. 25, 2013, said attorney Casey Moriarty in a blog posting for the Seattle-based law firm Ogden Murphy Wallace. But you should “also be mindful of the important terms in BAAs that can lead...

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