The Deadline for “Grandfathered” Business Associate Agreements is Approaching

Are all of your business associate agreements updated to comply with the HIPAA Omnibus Rule?  Hopefully the answer by this time is yes.  Generally, the deadline for compliance with the new requirements for BA agreements under the Omnibus Rule was September 23, 2013.  However, there was an exception under the Omnibus Rule for compliant BA agreements that were in writing prior to January 25, 2013 and were not subsequently modified or renewed.  These so-called “grandfathered” BA agreements are not required to be updated until September 23, 2014.  As is always the case, the year has passed quickly and the deadline for updating these “grandfathered” BA agreements is almost here.  Now is the time to once again review all of your BA agreements to ensure they satisfy requirements under HIPAA, including those agreements that have been in place for years and may have eluded your attention until now.  Nutile Pitz & Associates is here to help with this and all your HIPAA compliance needs … FOR THE HEALTH OF YOUR BUSINESS.