CMS Publishes Final Rule on Emergency Preparedness Affecting Medicare and Medicaid Providers and Suppliers

On September 16, 2016, the Centers for Medicare & Medicaid Services (CMS) published in the Federal Register a Final Rule entitled: Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers.

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:

 

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