I am trying to determine whether we want to pursue a BAA with our temp agency. It is my understanding that if we provide HIPAA training and the temp is under our supervision, we can opt to consider the temp employee to be a workforce member and a BAA is not necessary. However, it seems that a BAA could provide some sharing of the financial burden in the event of a breach. Can you help me identify the pros and cons for BAA vs workforce?
Janet Schumacher, RN, BSN, MPH, CHPC
My question would be whether or not the agency is receiving PHI and utilizing that PHI on behalf of the organization or is it just the temporary worker provided by the agency who has access to PHI. If the agency is not accessing PHI on your behalf I'm not sure a BAA would be appropriate.
Sherrie A. King
Appalachian Regional Healthcare System
Compliance Hotline: 1-800-656-7743
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