HIPAA Final Rule: Modification of Business Associate Definition, Part (5)–Subcontractors

February 13, 2013.  Today, we finish examining (3)—the third paragraph of four—of the business associate definition, as modified by the Final Rule:  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, which was published in the Federal Register on January 25, 2013.  The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Here is the last of three parts of this paragraph: “(3) Business associate includes:  (iii) A subcontractor that…

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HIPAA Final Rule: Modification of Business Associate Definition, Part (3)

February 11, 2013.  Today, we start to examine (3)—the third paragraph of four—of the business associate definition, as modified by the Final Rule:  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, which was published in the Federal Register on January 25, 2013.  The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Here is the first of three parts of this paragraph, (i), which is the subject of today’s…

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HIPAA Final Rule: Modification of Business Associate Definition, Parts (1) & (2)

February 8, 2013.  Today, we examine (1) and (2)—the first two parts of four—of the business associate definition, as modified by the Final Rule:  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, which was published in the Federal Register on January 25, 2013.  The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. As with its predecessor, the modified definition of business associate refers to “business associate means, with…

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