Business Associate Agreement

The settlement in the Accretive Health, Inc. PHI breach case provides a good example of how the blurring of the covered entity and business associate roles can backfire on parties that fail to sufficiently analyze and define such roles, not only at the outset of a relationship but throughout its duration and evolution.
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Ohio Health Plans, the public health care program overseen by the Ohio Department of Jobs and Family Services, reported that a PHI security breach had occurred on June 3, 2011 affecting 78,042 individuals, which had resulted from the theft of a laptop involving a business associate, Area Agency on Aging, Ohio District 5.
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