Health Information Management

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

HIM-HIPAA Insider, June 9, 2014

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Submit your HIPAA questions to Editor Jaclyn Fitzgerald at and we will work with our experts to provide you with the information you need.

Q. I am looking for any information that would help my organization determine how to define a credentials verification organization (CVO) under HIPAA guidelines. Per HHS, a CVO performs healthcare operations for a covered entity (CE) and would need to be HIPAA compliant. However, a CVO does not seem to fit the definition of healthcare provider, health plan, or clearinghouse.
A. If the CVO is an outside company that is providing services on behalf of your CE and needs access to PHI to do its job, the CVO would be considered a business associate (BA) of your organization. You would be required to have a BA agreement with the CVO, and it would be required to meet the requirements of a BA. If the CVO has access to provider information but not patient information, it does not meet the definition of a BA.
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’sBriefings on HIPAA newsletter.


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