My understanding is a CE is only required to report a BA's breach or violation to the 
Secretary in the event the BA cannot cure the breach OR the Agreement cannot be 
terminated.

Dee Warrington
Director, HIPAA and Regulatory Compliance
OAO HealthCare Solutions, Inc.
20955 Warner Center Lane
Woodland Hills, CA  91367
(818) 598-6606
Fax: (818) 598-3270
[EMAIL PROTECTED]


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-----Original Message-----
From: Francine Kaplan [mailto:[EMAIL PROTECTED]
Sent: Friday, March 28, 2003 6:54 AM
To: WEDI SNIP Privacy Workgroup List
Subject: BAA termination on material breach


Does a CE HAVE to report a BA to the Secretary if the CE discovered a breach and the 
BA cannot cure the breach after reasonable time and efforts?

Your thoughts are appreciated.  Thanks

Francine W Kaplan, DAG
(609) 777-3427

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