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Showing 3 posts in Business Associate Agreements.

Reminder: Update Your “Grandfathered” HIPAA Business Associate Agreements Now!

In January 2013, the Department of Health and Human Services (“HHS”) published its Final Rule, which significantly increased the privacy and security responsibilities for the “business associates” of “covered entities,” as those terms are defined by HIPAA. A provision within the Final Rule mandated that all covered entities and their business associates revise their business associate agreements to reflect the new responsibilities. Specifically, a business associate must now, among other things: More >

Have You Reviewed Your Existing Business Associate Agreements?

Pursuant to the HIPAA Final Omnibus Rule (“Final Rule”), covered entities and their business associates were required to enter into new business associate agreements (“BAAs”) or modify existing BAAs by Sept. 23, 2013. However, existing BAAs that (i) were entered into on or before Jan. 25, 2013; (ii) met the requirements that were applicable prior to the promulgation of the Final Rule; and (iii) were not modified after March 26, 2013, have until Sept. 23, 2014 to be updated. That deadline is quickly approaching. More >

HHS Issues Final HIPAA Omnibus Rule

The U.S. Department of Health and Human Services (“HHS”) recently announced its issuance of the highly-anticipated regulations or Final Omnibus Rule (“Rule”) relating to the modification of the HIPAA Privacy, Security, and Enforcement rules under the Health Information Technology for Economic and Clinical Health Act (“the HITECH Act”). 78 Fed.Reg. 17 Part II (January 25, 2013) modifying 45 CFR Parts 160, 162, 164. The Final Rule, 78 Fed.Reg. 17 Part II, 563 pages in length, makes significant changes of which all providers need to be aware. A complete examination of the sweeping changes cannot be done in one article, so we will make a general summary of the most important changes. More >

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