HITECH Act Final Rule Business Associate Agreement Compliance Date Was September 22, 2014; Time to Focus on Enforcement-Part 3

September 30, 2014.  HITECH Act Final Rule business associate (BA) provisions had to be reflected in business associate agreements no later than Monday, September 22, 2014.  On January 25, 2013, the Department of Health and Human Services (HHS) published in the Federal Register:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules,” v.78, n.17, pp. 5566-5702, which is available online at: http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.   The Final Rule modified the definition of business associate, and the timeframes for reflecting modified Final Rule provisions pertaining to business associates in a business associate agreement compliant with the Final Rule.  We discussed the modified definition and issues in the preceding six-part series on business associates, and recommended that readers review Sample Business Associate Agreement Provisions that also was published on January 25, 2013, by the Office for Civil Rights (OCR) of the Department of Health and Human Services (HHS).  That site can be accessed at: http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/contractprov.html

 

HITECH Act Final Rule Business Associate Agreement Compliance Date Was September 22, 2014; Time to Focus on Enforcement-Part 2

September 26, 2014.  HITECH Act Final Rule business associate (BA) provisions had to be reflected in business associate agreements no later than Monday, September 22, 2014.  On January 25, 2013, the Department of Health and Human Services (HHS) published in the Federal Register:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules,” v.78, n.17, pp. 5566-5702, which is available online at: http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.   The Final Rule modified the definition of business associate, and the timeframes for reflecting modified Final Rule provisions pertaining to business associates in a business associate agreement compliant with the Final Rule.  We discussed in the preceding six-part series on business associates, and recommended that readers review Sample Business Associate Agreement Provisions that also was published on January 25, 2013, by the Office for Civil Rights (OCR) of the Department of Health and Human Services (HHS).  That site can be accessed at: http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/contractprov.html

 

 

HITECH Act Final Rule Business Associate Agreement Compliance Date Was September 22, 2014; Time to Focus on Enforcement-Part 1

September 25, 2014.  HITECH Act Final Rule business associate (BA) provisions had to be reflected in business associate agreements no later than Monday, September 22, 2014.  On January 25, 2013, the Department of Health and Human Services (HHS) published in the Federal Register:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules,” v.78, n.17, pp. 5566-5702, which is available online at: http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.   The Final Rule modified the definition of business associate, and the timeframes for reflecting modified Final Rule provisions pertaining to business associates in a business associate agreement compliant with the Final Rule.  We discussed in the preceding six-part series on business associates, and recommended that readers review Sample Business Associate Agreement Provisions that also was published on January 25, 2013, by the Office for Civil Rights (OCR) of the Department of Health and Human Services (HHS).  That site can be accessed at: http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/contractprov.html

 

 

Deadline in 3 Days to Comply with Final Rule Business Associate Agreement Provisions—Part 6: Exclusions

Friday, September 19, 2014.  HITECH Act Final Rule business associate (BA) provisions must be reflected in business associate agreements no later than Monday, September 22, 2014.  On January 25, 2013, the Department of Health and Human Services (HHS) published in the Federal Register:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules,” v.78, n.17, pp. 5566-5702, which is available online at: http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.   The Final Rule modified the definition of business associate, and the timeframes for reflecting modified Final Rule provisions pertaining to business associates in a business associate agreement compliant with the Final Rule, which we outlined in Part 1.

Deadline in 4 Days to Comply with Final Rule Business Associate Agreement Provisions—Part 5: Subcontractors

September 18, 2014.  HITECH Act Final Rule business associate (BA) provisions must be reflected in business associate agreements no later than Monday, September 22, 2014.  On January 25, 2013, the Department of Health and Human Services (HHS) published in the Federal Register:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules,” v.78, n.17, pp. 5566-5702, which is available online at: http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.   The Final Rule modified the definition of business associate, and the timeframes for reflecting modified Final Rule provisions pertaining to business associates in a business associate agreement compliant with the Final Rule, which we outlined in Part 1.

Deadline in 5 Days to Comply with Final Rule Business Associate Agreement Provisions—Part 4

September 17, 2014.  HITECH Act Final Rule business associate (BA) provisions must be reflected in business associate agreements no later than Monday, September 22, 2014.  On January 25, 2013, the Department of Health and Human Services (HHS) published in the Federal Register:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules,” v.78, n.17, pp. 5566-5702, which is available online at: http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.   The Final Rule modified the definition of business associate, and the timeframes for reflecting modified Final Rule provisions pertaining to business associates in a business associate agreement compliant with the Final Rule, which we outlined in Part 1.

 

Deadline in 6 Days to Comply with Final Rule Business Associate Agreement Provisions—Part 3

September 16, 2014.  HITECH Act Final Rule business associate (BA) provisions must be reflected in business associate agreements no later than Monday, September 22, 2014.  On January 25, 2013, the Department of Health and Human Services (HHS) published in the Federal Register:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules,” v.78, n.17, pp. 5566-5702, which is available online at: http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.   The Final Rule modified the definition of business associate, and the timeframes for reflecting modified Final Rule provisions pertaining to business associates in a business associate agreement compliant with the Final Rule, which we outlined in Part 1.

Deadline in 7 Days to Comply with Final Rule Business Associate Agreement Provisions—Part 2

September 15, 2014.  HITECH Act Final Rule business associate (BA) provisions must be reflected in business associate agreements no later than Monday, September 22, 2014.  On January 25, 2013, the Department of Health and Human Services (HHS) published in the Federal Register:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules,” v.78, n.17, pp. 5566-5702, which is available online at: http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.   The Final Rule modified the definition of business associate, and the timeframes for reflecting modified Final Rule provisions pertaining to business associates in a business associate agreement compliant with the Final Rule., which we outlined in Part 1.

 

Deadline in 10 Days for Compliance with HITECH Act Final Rule Business Associate (BA) Provisions—Part 1: Modified BA Definition

September 12, 2014.  HIPAA Safeguard is starting today a six part series that will run through Friday, September 19, 2014, that covers the HITECH Act business associate provisions that must be reflected in business associate agreements no later than Monday, September 22, 2014.  On January 25, 2013, the Department of Health and Human Services (HHS) published in the Federal Register:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules,” v.78, n.17, pp. 5566-5702, which is available online at: http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.   The Final Rule modified the definition of business associate, and the timeframes for reflecting modified Final Rule provisions pertaining to business associates in a business associate agreement compliant with the Final Rule.  Before presenting the modified BA definition, we present again from the post on September 7, 2014, as a reminder, the timeframes in the Final Rule:

 

OCR Enforcement, Investigation, and Reviews of Willful Neglect HIPAA Violations from January 25, 2013 Final Rule Provisions

In two earlier posts, we discussed the Compliance Audits under the Centers for Medicare & Medicaid Services (CMS) Financial Incentive Programs for Adoption and Meaningful Use of Certified Electronic Health Record (EHR) Technology.  In this post, we discuss enforcement, investigation, and review of the HIPAA Privacy and Security Rules and the HITECH Act Breach Notification Rule by the Department of Health and Human Services (HHS) Office for Civil Rights (OCR) as provided in the January 25, 2013 Final Rule, entitled:  “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act:  Other Modifications of the HIPAA Rules.” [hereinafter, “Modifications”]  This Final Rule, also known as the Omnibus Rule, was published in the Federal Register on the date noted, at v.78, n.17, pp. 5566-5702, and is available online at:  http://www.gpo.gov/fdsys/pkg/FR-2013-01-25/pdf/2013-01073.pdf.

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