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
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
A few days ago, after making multiple attempts on behalf of a client to verify and clarify how join.me supports HIPAA compliance, specifically participating in Business Associate Agreements, I found that they do not. In fact, they do not consider themselves subject to HIPAA regulations, regardless of the possibility of PHI being stored on the … Read more
If you’re a digital health vendor with an EHR product, take heed. Simply because your client hasn’t paid you for implementation, or you’ve had a disagreement about the product, doesn’t mean you can refuse them access to the EHR and the ePHI within. It’s a HIPAA violation. You can check out the FAQ, aka the … Read more
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