Most of us who work in healthcare knew that a final rule for HIPAA would happen this year. In January, the Omnibus Rule was posted and it became effective on March 26, 2013.
The good news is that we have time to comply with the rule and several areas have extensions that will allow us all time to understand the rule and put the necessary changes in place. That being said, we all need to start making these changes now if we haven’t already done so.
As a transcription vendor, I am a Business Associate (BA) and already have Business Associate Agreements (BAA) in place. There are a lot of changes for the BA, and I would encourage both Business Associates and Covered Entities to take a close look at these changes. I also encourage both the Business Associates and Covered Entities to talk with each other about what this rule means to both sides.
I have always believed in open communication with my clients and this is an area that is no different. We can’t assume that just because the rule is out that either a vendor or a client understands completely what this change means to its organization. The only way to ensure we are all on board with the change is to have that open dialogue.
Your Business Associate Agreements will need to be changed. A sample Business Associate Agreement posted by HHS is available at www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/contractprov.html. I know that in the coming weeks I will be contacting each of my clients to discuss the changes needed to the BAA. I encourage each of you, whether you are a Covered Entity or a Business Associate, to do the same.
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