Health Information Management

HIPAA Q&A: You’ve got questions. We’ve got answers!

HIM-HIPAA Insider, November 17, 2014

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Submit your HIPAA questions to Editor Jaclyn Fitzgerald at jfitzgerald@hcpro.com and we will work with our experts to provide you with the information you need.
 
Q: I work for a small hospital that recently received requests to sign BAAs with physician practices in the area whose patients we treat. I have heard that BAAs are required for BAs who are dealing with PHI, but are not required when the relationship is based on providing direct patient care. I do not think we need to sign these BAAs. What is correct under HIPAA?
 
A: You are correct. Since your hospital is not providing services on behalf of these physician practices, they are not BAs. However, you may share PHI with them as part of the treatment process. Your hospital would be a BA of the practices if it performed specific services, such as billing, for them.
 
Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS, vice president of health information at Baylor Scott & White Health in Temple, Texas, answered this question for HCPro's Briefings on HIPAA newsletter.
 

 

 



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