How are organizations classifying Board of Directors or Trustee members?  Workforce -- or since they are not "under the direction" of the covered entity, but have a need from time to time, to receive PHI, or might they better be classified as “business associates” and need a business associate agreement?

Leslie C. Bender

General Counsel/Privacy Official
ROI Companies

1922 Greenspring Drive, Suite 7
Timonium, Maryland  21093





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