K&L Gates Triage: HIPAA: Do Hospitals Need a Business Associate Agreement with their Health System Parent Corporation?


Manage episode 270034191 series 1533910
By K&L Gates and L Gates. Discovered by Player FM and our community — copyright is owned by the publisher, not Player FM, and audio is streamed directly from their servers. Hit the Subscribe button to track updates in Player FM, or paste the feed URL into other podcast apps.

In this week’s episode, Rebecca Schaefer and Hannah Maroney discuss a string of recent HIPAA enforcement actions which demonstrate that the HHS Office of Civil Rights (OCR), the agency tasked with enforcing HIPAA, is increasingly focused on ensuring that affiliated hospitals within a health system, typically comprising an Affiliated Covered Entity (ACE), have HIPAA business associate agreements in place with the parent corporation to allow for the lawful exchange of PHI. The presenters discuss the circumstances in which a business associate agreement may be required, and address several questions regarding related ACE organizational considerations.

Presenters: Rebecca Schaefer, Hannah Maroney

143 episodes