[ Monday, November 18, 2013 ]


A Covered Entity can be a Business Associate of another Covered Entity.  This is well-settled ("A covered health care provider, health plan, or health care clearinghouse can be a business associate of another covered entity") from the beginning of HIPAA, but some people continue to think that since their client is a covered entity, it need not sign a business associate agreement when it provides services for another covered entity and creates, receives, maintains or transmits PHI in connection with the services. 

Jeff [11:19 AM]

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