Tip: Know your BAs
HIPAA Weekly Advisor, January 11, 2010
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As of February 17, all business associates (BAs) must comply with the HIPAA security rule and parts of the privacy rule or face stiff penalties.
Double-check your list of BAs, says Kate Borten, CISSP, CISM, president of The Marblehead Group in Marblehead, MA. Make sure that anyone who could qualify as a BA has been accurately identified as a BA. For example, your organization may not realize that a consultant that has access to PHI actually qualifies.
Make sure organizations you have identified as BAs actually are, says Frank Ruelas, director of compliance and risk management at Maryvale Hospital and principal, HIPAA Boot Camp, in Casa Grande, AZ.
Also, make sure you haven’t failed to identify a BA, which can also lead to problems.
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