HIPAA Business Associates

Our partner Elizabeth Litten and I were recently featured again by our good friend Marla Durben Hirsch in her article in the April 2017 issue of Medical Practice Compliance Alert entitled “Business associates who farm out work create more risks for your patients’ PHI.” Full text can be found in the April, 2017 issue, but

According to the latest HIPAA-related guidance (Guidance) published by the U.S. Department of Health and Human Services (HHS), a cloud service provider (CSP) maintaining a client’s protected health information (PHI) is a business associate even when the CSP can’t access or view the PHI. In other words, even where the PHI is encrypted

Congratulations!  You have a HIPAA-compliant business associate (or subcontractor) agreement in place – now what? How can you implement the agreement without becoming a HIPAA guru?

There are many resources available that offer detailed guidance on risk analysis and implementation protocols (such as the Guide to Privacy and Security of Electronic Health Information published by

Our partner Bill Maruca, who is the Editor and a frequent contributor to this blog, was recently interviewed by PracticeSuite as part of their Expert Interview program.  In the course of his interview, Bill discusses patient confidentiality, keeping records safe and private, and trends in the medical billing industry. 

One important recommendation by Bill

Nearly a year ago, as described in an earlier blog post, one of my favorite health industry journalists, Marla Durben Hirsh, published an article in Medical Practice Compliance Alert predicting physician practice compliance trends for 2014.  Marla quoted Michael Kline’s prescient prediction that HIPAA would increasingly be used as “best practice” in actions brought

The Connecticut Supreme Court handed down a decision in the case of Byrne v. Avery Center for Obstetrics and Gynecology, P.C., — A.3d —-, 2014 WL 5507439 (2014) that

[a]ssuming, without deciding, that Connecticut’s common law recognizes a negligence cause of action arising from health care providers’ breaches of patient privacy in the context of

The deadline for executing a HIPAA Omnibus Rule-compliant Business Associate Agreement (BAA) looms just 2 short weeks from today.  What can a busy covered entity (CE) or business associate (BA) do quickly to show HHS (let alone its business partners/contractors) that it wants and fully intends to comply with the new requirements?  Here are  3