Corporate Compliance

New BA requirements call for new contract language

Strategies for Health Care Compliance, November 1, 2009

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The privacy and security changes pursuant to the Health Information Technology for Economic and Clinical Health (HITECH) Act (Subtitle D—Privacy) are quickly evolving from words on paper to a real need for new and revised organizational policies, procedures, and contracts. The security breach notification interim final rule became effective September 23, and the deadline for amending business associate (BA) contracts is only four months away—February 17, 2010.

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