Health Information Management

Q&A: Tracking BA agreements

HIPAA Weekly Advisor, August 24, 2009

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Q. Generally, who in a hospital maintains and tracks business associate (BA) agreements? Is it information systems staff members, the security officer, the compliance officer, or someone else?

A.
The procedure for handling BA agreements varies from one organization to the next. Many organizations require legal counsel to review all contracts before they are finalized, and this is a good way to ensure that contracts include a BA agreement if necessary. Legal counsel may have responsibility for maintaining a database of all contracts. Alternatively, the compliance or materials management staff may do this.

Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS, answered this question. This is not legal advice. Consult your attorney regarding legal matters.



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