HIPAA

Clinical Lab Contractor for Skilled Nursing Facility

  • 1.  Clinical Lab Contractor for Skilled Nursing Facility

    Posted 06-05-2020 03:13 PM

    Is it common for clinical labs to try to get Skilled Nursing Facilities the labs does testing for, to sign a BAA with the lab as the BA and the SNF as the covered entity?

     

    Thanks

     

     


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    Steve Paterson CHC, CHPC
    Chief Quality and Compliance Officer

    United Church Homes and Services
    100 Leonard Ave
    Newton, NC 28658

    Phone: 828-465-8022
    Email: SPaterson@uchas.org
    Web: www.uchas.org

     


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  • 2.  RE: Clinical Lab Contractor for Skilled Nursing Facility

    Posted 06-05-2020 03:49 PM
    Not sure what you are asking for here Steve so lets start with the basics. A BAA is required when a covered entity contracts with an outside vendor, not a member of the covered entity's workforce, to perform tasks on behalf of the covered entity for which access to the PHI of the covered entity's patients is required. 

    Medical reference labs and  dental labs typically work on behalf of the patient, not the ordering physician or facility.  As the lab is a covered entity working on behalf of the patient a BAA is not normally required.  

    Guidance from HHS:



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  • 3.  RE: Clinical Lab Contractor for Skilled Nursing Facility

    Posted 06-05-2020 04:30 PM
    For some reason the guidance from HHS seems to be missing from my original response. Here it is.



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  • 4.  RE: Clinical Lab Contractor for Skilled Nursing Facility

    Posted 06-05-2020 04:32 PM
    Still missing, not sure why Here is the link



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