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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----- 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 Dominion
Dental Services, Inc. Phn:
(703) 518-5000 ext. 3035 ******************************************* If you
are not the intended recipient, any disclosure, copying, distribution or any
action taken or omitted to be taken in reliance on it is prohibited and may be
unlawful. *********************************************************************
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Business Associate Agreement.doc
Description: MS-Word document
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