[ Friday, January 25, 2013 ]


Model Business Associate Agreement Provisions: way back when the Privacy Rule first came out, HHS helpfully provided a draft business associate agreement.  Unfortunately, it was very popular.  I say unfortunately because it wasn't a very well-drafted contract.

In the Omnibus Rule and commentary that came out around that time, HHS said it was publishing model business associate agreement language.  The old language was still up on the website, until today.  Now, there's a new item on the HHS website with new, model BAA language.  And unlike last time, HHS didn't try to draft a whole contract; rather, they just gave model language that, on first glance, looks pretty promising.

Officially, the Omnibus Rule is published in today's Federal Register (even though it's been available online for over a week), so today is fine for posting up the model BAA language.

Jeff [4:10 PM]

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