Does your business associate agreement (BAA) reflect your business deal, or is it a bare bones HIPAA compliance document?

Now is the time to check. The HIPAA “Omnibus Rule” published in January of 2013 gave covered entities, business associates, and subcontractors until September 22, 2014 to make their business associate agreements (BAAs) compliant, so use

Where did the time go?  Today’s the day – September 23, 2013.  This is compliance day for most of the Omnibus Rule changes.  I had a feeling this deadline would catch up with me faster than I would be able to blog my 10 tips, so I’m going to count “TIP TWO” as tips TWO

Unless the Department of Health and Human Services (HHS) makes another last-minute, litigation-inspired decision to delay the September 23, 2013 compliance date, we’re well into the 10-day countdown for compliance with most of the Omnibus Rule requirements.  Here’s “TIP THREE” —

TIP THREE:

Covered Entities and Business Associates:  make sure you know where your Protected

Our partner Keith McMurdy posted a timely summary of the requirements of the HIPAA Omnibus Rule for employers and benefit plan sponsors at his Employee Benefits Legal Blog.  It is reproduced below:

Lost in the Shuffle: The September 23 HIPAA Notice Requirements

By Keith R. McMurdy on September 6, 2013Posted in Plan Administration,