When a copy of the BAA is requested, be
sure to get the name of the business associate
and nature of service that they will be
providing to your organization. Type the name
of the business associate into the agreement
and get it signed by your company’s
authorized signer prior to sending the
agreement out. Be sure and ask the business
associate for a counter-signed copy to be
returned to you for your record keeping. For
tracking purposes, keep a list of each business
associate along with their contact information,
what services they are providing, the name of
your organization’s department and manager
who is contracting with the business associate,
and the date that the agreement was signed by
the business associate. This will be a lifesaver
if you are ever audited.
In the event that the business associate
requests to use their BAA, be sure to send it
to your Legal department for review prior to
having it signed. Likewise, if they want to sug-
gest changes or “red-line” your organization’s
BAA, be sure to have those changes approved
by your legal counsel. One would think that
these agreements are all the same, but this is
not always the case. Some business associates
will sign and return your BAA with no ques-
tions asked. However, others will go through
multiple red pens suggesting changes that are
mostly in their favor.
Once the final version of the BAA is signed
by both parties, keep an electronic copy and
a hard copy of the agreement. You may also
want to keep any email correspondence with
business associates if you need to refer to that
for future reference.
Keeping track of business associates and the
BAAs that come with them can be difficult
but, with some education and cooperation, it
can be done.
1. HHS.gov: Health Information Privacy: Business Associates.
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