Are All of Your BAAs Signed?
The deadline for having revised business associate agreements (BAAs) in place is September 22nd, which is only one week away. If you have sent BAAs out to your business associates and haven’t received them back, you should follow-up this week to ensure the agreements are executed by the deadline. If a business associate creates, receives, maintains or transmits protected information on behalf of your plan after September 22nd without a valid BAA in place, you could be subject to a civil penalty of up to $50,000 per violation. To avoid writing a huge check to HHS, we recommend that you do one more review of your potential business associates and make sure that you have all of your BAAs signed by September 22nd.