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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