Will billing services be considered “business associates,” and will we need a business associate agreement in order to share the health information that is presently provided at their written request?
A billing service would be a business associate acting on the physical therapist’s behalf. You need a business associate contract that, among other things, confirms that the billing service is operating on his or her behalf and defines the information that the billing service is allowed to receive. If you already have a contract with the billing service, you can still utilize that contract for one year past the April 14, 2003, compliance date. After that, you should have another contract in place that contains the provisions that are “suggested” by Health and Human Services in their model business associate contract. If you do not have a contract with the billing service, you should devise one prior to the April 14, 2003, compliance date.
Related Questions
- Will billing services be considered "business associates," and will we need a business associate agreement in order to share the health information that is presently provided at their written request?
- What are some considerations in developing and implementing a business associate agreement with a health information organization (HIO)?
- May a covered entity share protected health information directly with another covered entity’s business associate?
