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  1. Hello, I'm stumped and just need a reality check. Here's the pretty simple fact pattern: A public School District and a local Community Clinic (a health care provider) have entered into an arrangement whereby the Clinic will provide a day of health screenings for students in the District. The Clinic has asked the District to sign a Business Associate Agreement. The Agreement identifies the Clinic as the Busniess Associate. The District is referred throughout the agreement as the 'Facility' (where screenings will occur). And the Agreement refers to services provided on for or on behalf of a Covered Entity (which is not defined). I asked them to identify the CE, and the Clinic to me it is the District?!?!?!!? (That must be incorrect - District is not a health care provider, and not a CE). Just to clarify, the District's Health Plan has no involvement here. This is just a Clinic (a CE) coming in to provide student health screenings. It is not clear to me why a business associate agreement is even needed, in that the District won't be providing services for, or on behalf of, the Clinic that require the use or disclosure of information. Do you agree? If the parties insist on having an agreement in place, I want to ask them to clarify that the Clinic is the CE, and that the District is a BA, but only to the extent that it should provide any services for or on behalf of the Clinic. Thoughts? Thank you!
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