HIPAA

Interface with other healthcare facilities

  • 1.  Interface with other healthcare facilities

    Posted 09-10-2020 09:06 AM
    When setting up an interface with a hospital or other healthcare facilty are you getting any other agreements in place other than a BAA? I feel like this might be a legal question but thought I would start here. I feel like something more is needed other than just a BAA (agreement with monetary penalities, insurance requirements, indemnification, etc. for this type of connection but the risks are equal both ways and according to our IT Director there are very little vulnerabilities that would warrant more than the protections the BAA states but I am paranoid about it. Thoughts?

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    Savannah Knuettel
    Compliance Officer
    Galen Medical Group
    Hixson,TN

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
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    19th Annual CEI Virtual Conference


  • 2.  RE: Interface with other healthcare facilities

    Posted 09-10-2020 09:42 AM
    Good morning, Savannah

    I have seen a separate Service Contract that includes some of the elements that you mention (and much more.)  

    Looking forward to seeing what others have to say.

    Best regards,
    Susan Hammerschmidt 



    19th Annual CEI Virtual Conference


  • 3.  RE: Interface with other healthcare facilities

    Posted 09-11-2020 08:20 AM
    I'm not clear on the scenario and whether this situation is a BA arrangment or something else. Regardless of the arrangement, yes you would want basic contractual provisions regarding things such as compliance with laws, reporting of breaches, indemnification.

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    Brenda Manning J.D., C.H.C., C.H.P.C.
    Privacy Director
    Interim Privacy Officer
    Carilion Clinic

    The views expressed herein are my own and do not represent those of my employer. They are not meant to constitute legal advice or create an attorney-client relationship.
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    19th Annual CEI Virtual Conference