Notice & DisclosureRecurring
HIPAA Business Associate Agreements (BAAs)
HIPAA; 45 CFR § 164.502(e), 164.504(e)
Self-insured plans must execute BAAs with all vendors/service providers that create, receive, maintain, or transmit PHI on behalf of the plan (TPAs, brokers handling PHI, PBMs, wellness vendors, etc.).
ResponsibleClient/Other TPA (compliance TPA)
Deliver ToBusiness associates (TPAs, PBMs, brokers, etc.)
DeadlineBefore sharing PHI with any business associate; review/update at contract renewal
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