Health Information Management

Defining BAs

HIM-HIPAA Insider, November 3, 2009

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The Privacy Rule defines a BA as a person or an organization, other than a member of the CE’s work force, that performs function on behalf of the CE or provides services to the CE that involve the use or disclosure of PHI.
 
Functions that a BA may perform for a CE include billing, claims processing, data analysis, and utilization review. BA services to a CE include legal, actuarial, accounting, consulting, data aggregation, and financial services.
 
Not all vendors are considered BAs. If a vendor doesn’t need access to PHI to provide services to the CE, that vendor is not a BA, and merely having incidental or accidental access to PHI doesn’t make the vendor a BA. Examples of vendors that not considered BAs include delivery companies, environmental services companies, and management consultants.
 
Note: This excerpt is adapted from the HCPro book The Privacy Officer’s Handbook, by Mary D. Brandt, MBA, PHIA, CHE, CHPS. For ordering information, visit the HCMarketplace or call 887-727-1728.



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