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Guest jdsmith
Posted

A business associate wants to have one BA agreement with its clients. Is it possible for the client (employer) as plan sponsor to execute one BA agreement with the BA that will cover all activities between BA and the various plans of the client?

I am finding difficulty finding anything that says I cannot do this.

thanks for any thoughts.

Posted

All of the group health plans sponsored by an employer may be considered an "organized health care arrangement".

There is nothing I am aware of that would prevent the OHCA from entering into a BAA with the business associate as a group (so long as the provisions of the BAA apply to all of the individual plans).

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