Title: PRIVACY: BA Agreements
Deborah,
Attached
is the BA Agreement we are using with our contract vendors, as well as with
those vendors who are on a fee-for-service basis, when the service meets the
definition of a BA activity.
For those
with whom we have an existing contract, (Professional Services Agreement), the
Business Associate Agreement is a stand-alone document. By handling the agreements in this way
we avoid having to amend or addend each underlying contract individually which,
due to our organizational structure, would require each such amendment or
addendum to be presented to the Board of Supervisors for specific approval. Because we often have multiple
underlying contracts with our vendors this approach greatly facilitates the
process, particularly when those associated contracts vary in duration. To further simplify the initial
implementation we are presenting all BA Agreements to the Board at once for
collective approval. Each BA
Agreement remains in effect for the term(s) of any associated contract(s),
without the necessity for separate annual review of the BAA itself, while still
allowing for each such underlying contract, as well as the BAA, to be independently
negotiated and enforced. In addition,
because the unique terms, scope and “Authorized Purposes” for the use of PHI
are set forth in the Exhibit attached to each Business Associate Agreement, future
revisions are simplified and there is no need to “tweak” the content of each
and every BAA to suit the individual vendor.
Cheri
Huber
County
Privacy Officer
County of
Napa
1195 Third
Street, Room 301
Napa,
CA 94559
707-253-4523
-Original
Message-
From: Deborah Campbell
[mailto:[EMAIL PROTECTED]
Sent: Thursday, March 13, 2003
1:26 PM
To: WEDI SNIP Privacy Workgroup
List
Subject: PRIVACY: BA Agreements
I have drafted a BA
Addendum and a BA Agreement. We will use the addendum with anyone we have a
contract with. However, there are certain entities that do fee-for-service for
us and do not have contracts (printing companies, lawyers, temp agencies, etc.)
For these entities we will use the BA Agreement. I'm trying to make the
language vague enough to work for all BA's so that as little tweaking has to be
done for individual entities. But I'm having trouble with this, since we have
to list the "permitted and required uses and disclosures." The
Addendum is easier because the original contracts say what they are using the
info for.
Is anyone willing share
how they are handling this? Or does anyone have a BA Agreement (not addendum)
at I could see to get an idea of how they are doing this?
Deborah
Campbell
Compliance Coordinator
Dominion
Dental Services, Inc.
115 South Union Street,
Suite 300
Alexandria, Virginia
22314
Phn:
(703) 518-5000 ext. 3035
Fax: (703) 518-8849
Toll Free:
888-518-5338
Email: [EMAIL PROTECTED]
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Business Associate Agreement.doc
Description: MS-Word document
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The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions
on this listserv therefore represent the views of the individual participants, and do
not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If
you wish to receive an official opinion, post your question to the WEDI SNIP Issues
Database at http://snip.wedi.org/tracking/. These listservs should not be used for
commercial marketing purposes or discussion of specific vendor products and
