The HIPAA Omnibus/Final Rule, published on January 25, 2013, grandfathered valid HIPAA Business Associate agreements prior to that date until September 22, 2014. That grace period is rapidly coming to an end.
Department of Health and Human Services (HHS) defines “business associate” associate as “a person or entity, other than a member of the workforce of a covered entity, who performs functions or activities on behalf of, or provides certain services to, a covered entity that involve access by the business associate to protected health information. This includes subcontractors that create, receive, maintain, or transmit protected health information on behalf of another business associate.
The specifications for the Business Associate Agreement have changed so covered entities that took advantage of this grace period must now update all Business Associate Agreements dated prior to 1/25/2013. Eagle Consulting Partners offers a model Business Associate Agreement which covered entities may adapt.
It may be good to review more recent agreements to verify that they are compliant with the new specifications.
Eagle Consulting Partners is pleased to make available for download, our standard HIPAA Business Associate Agreement template here – BA – Model Omnibus Compliant.
Download and customize your business associate agreements using our model before September 24, 2014. The file is a Microsoft Word Document.
If you have any questions or need other assistance with HIPAA Compliance, please call Eagle at 216.503.0333 x. 101.
