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BAs and BAAs
BAs and BAAs
Posted 19 days ago
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Someone asked me offlist to clarify my posting that a Business Associate (BA) is not determined by whether a Business Associate Agreement is signed but rather when an entity meets the definition of a Business Associate such as when it receives PHI from a Covered Entity and stores that PHI in the cloud for that Covered Entity.
This person shared that they received guidance from a subject matter expert that a BA is not a BA until it signs a BAA, period. Glad this person asked the question because I know how frustrating it can be to get different answers when the answer is literally black and white. No need to make things more confusing.
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