HIPAA Q&A: BA contracts
HIPAA Weekly Advisor, November 8, 2010
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Q. An answering service has a business associate (BA) agreement with another BA, which has a BA agreement with a covered entity (CE). Must the answering service have a BA agreement directly with the CE?
A. The answer to your question depends on the relationship between the answering service and the CE. If the answering service provides services directly to the CE and bills the CE for its services, the CE should have a BA agreement with the answering service.
But if the answering service is an agent of another company, such as a practice management company, that provides services to the CE, and that company bills the CE, the answering service does not need a BA agreement with the CE. As an agent of the BA, it still must comply with HIPAA, however.
Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS, answered this question. She is a nationally recognized expert on patient privacy, information security, and regulatory compliance and is associate executive director of Health Information Management (HIM) at Scott & White Healthcare in Temple, TX. Some of her publications were used as a basis for the Health Insurance Portability and Accountability Act of 1996 privacy regulations. Advice given is general. Readers should consult professional counsel for specific legal, ethical, or clinical questions.
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