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Is a business associate agreement needed with a payroll vendor?


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Guest RedShoes
Posted

Our payroll vendor currently receives names, address, date of birth of all of our ee's, as well as whether our ee's are taking flex med deductions and deductions for health and dental.

Under this circumstance, is the above information considered PHI and should we therefore be asking our payroll vendor to sign a business agreement?

Posted

I don't think a BAA is needed here. This seems like enrollment & eligibility information held by the employer, which is specifically excepted from the definition of PHI.

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