I wanted to get input regarding Billing Services that use contractors to perform certain services.  My understanding is the Billing Service is considered a Business Associate and not a covered entity.  If that is true, would the contractors working for a billing service be Business Associates of a Business Associate and would they sign a similair BA agreement as the billing service did but between them and the billing service??

I look forward to everyone’s intepretation as even our attorney is a bit confused.

 

 

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