Managed Care

  • 1.  BA Agreements

    Posted 03-28-2013 12:23 PM
    This message has been cross posted to the following eGroups: Managed Care and HIPAA .
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    Hi folks,

    I'm trying to clarify my understanding and some practical implications of the final rule.  If I understand, the new rule was effective on March 26, but won't be enforced until September 23.  Also, we don't have to modify BA Agreements in effect January 25 with no changes between March 26 and September 23 before September 2014 or contract renewal, whichever comes first.  Is this a clear understanding? 

    However, the new rules apply to BAs now and if CEs wait until contract renewal to update the BA agreeement, what are the CE risks?  Do BAs have an independent obligation to enter into BA agreements with subcontractors now if they enter into business relationships after March 26? 

    Is there any wisdom in proceeding now or with all reasonable speed to get all BAs updated?  How are others approaching this issue?
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    Sharon Hockett JD
    Auditor
    Agate Healthcare
    Eugene,OR
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