HIPAA

Latest Discussion Posts

  • True...but as people have shared in the past...and a question that comes up often...it is not common that a BAA is acting as an agent of a CE.  So in Carl's example, if there was an agency relationship, correct...the BA's knowledge or discovery of the ...

  • ​A nice question Erin, we have had this discussion many times with counsel. We specifically point out in our Professional Services Contracts and BAA that we do not have a "agency" relationship. I would suspect that an agency relationship would likely ...

  • ​Carl, I was under the impression that the 60 days started at the time the BA discovered the breach because it states under 164.404 "A covered entity shall be deemed to have knowledge of a breach if such breach is known, or by exercising reasonable diligence ...

  • When looking at any potential HIPAA incident, I look at the actions of the CE and/or BA and determine if there was an impermissible AAUD on their part; i.e., first steps first, not outcome and backtrack. So, here I read the scenario as CE sends MR to ...

  • :) ------------------------------ Carl Russell Compliance Analyst Delta Dental of Idaho Boise,ID Anything I say is my sole opinion and not of my company. ------------------------------