We are in the process of developing standard language "modules" that we would insert into our standard contract based on need:
Business Associate, Chain of Trust and Information Trading Partner. In some cases we would use all three, in others just one or two. I can send you the business associate "module' if you are interested.
Julie Fulcher
HIPAA Project Manager
Presbyterian Healthcare Services
Albuquerque, New Mexico 87125-6666
(505) 923-6397
[EMAIL PROTECTED]
-----Original Message-----
From: David Ermer [mailto:[EMAIL PROTECTED]]
Sent: Friday, March 08, 2002 10:05 PM
To: [EMAIL PROTECTED]; [EMAIL PROTECTED]
Cc: [EMAIL PROTECTED]
Subject: Re: Chain of Trust and BA agreements
I am attorney. It is a common practice to use one contract to serve multiple purposes. Just compare this to a situation where a company buys several different products simultaneously from one manufacturer. It would defy common sense to use separate agreements in wither that situation or this one. The law should reflect common sense, and generally it does. I concur with Beth. Best regards, David Ermer, Gordon & Barnett, Wash. D.C.
<<< "Beth Kranda" <[EMAIL PROTECTED]> 3/ 8 8:14p >>>
Yes, I have heard CMS say that it was not the intent that you have 3 agreements with each
of your trading partners. They may be combined to the extent that the trading partner is
also a BA.
I am no lawyer, however so let's hear what they have to say!
"Street, Bunny" wrote:
> Is anyone considering possibly combining these agreements? I realize they
> represent separate issues but do have some similarities. Comments
> appreciated.
> Thanks,
> Leslie Street
> Privacy Specialist
> Mountain States Health Alliance
> 423-431-1661
>
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OASYS
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