Looks like it could be a thing. All business associates (BAs), from super small, like small agency web hosting companies or medical transcriptionists, to large TPAs or data aggregation services, need to pay attention. The recent settlement of Jelly Bean Communications LLC with the Department of Justice – yes, you read that right, the DOJ … Read more
Well, remember the issues around what the “HIPAA exemption” in the California Consumer Privacy Act (CCPA) really applied to? We wrote about it here all the way back in May 2019. Turns out our impression was correct – so correct that California just passed a law to correct it! Here’s the skinny: On September 5, … Read more
Ever run into a vendor who claims to be a conduit versus a business associate (BA)? It happens all too often, in my experience. Here’s the problem: the conduit exception is a narrow one. If you’re storing PHI data, even encrypted PHI where you don’t have the encryption key, you’re a BA. Sign the Business … Read more
In a recent LinkedIn discussion between colleagues in our HIPAA Survival Guide group, a member posed an interesting question that probably doesn’t usually garner much attention in the general scheme of things when upgrading technology: If a company is a HIPAA Covered Entity and is migrating to Microsoft Office 365 (which is a cloud-based solution) … Read more
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