Health Information Management

Plan for compliance assurance with business associate contracts

HIM-HIPAA Insider, October 27, 2009

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To ensure compliance with the business associate and BAC requirements in HIPAA and HITECH, canvass business associates and BACs annually though the following actions:
  • Send a list of current business associate contracts to departments that use their services.
  • Request verification of the continued relationship.
  • Identify any necessary changes to the contract.
  • Ask that any additional business associates be identified.
Some organizations hold department managers accountable for obtaining the BAC. If this is customary, add a review of the contracts that have been signed to the compliance assurance program. A checklist of key elements should be readily available to anyone signing contracts. These key elements should include the HIPAA requirements as well as any other items deemed critical by your organization and your legal counsel. Remediation is necessary if a BAC is found to be out of compliance.
Note: This information is fromthe Guide to HIPAA Auditing, Second Edition, by Margret Amatayakul, MBA, RHIA, CHPS, CPEHR, FHIMSS. For ordering information, visit the HCMarketplace or call 887-727-1728.

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