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Proposed Modifications to HIPAA Privacy and Security Rules
Merion Matters 
[Guidance Overview] Aug. 16, 2010
Excerpt: A determination of whether a business associate or subcontractor is an agent for whom the principal is vicariously liable under the Proposed Rule or is instead an independent contractor requires a case-by-case inquiry based on the facts of the relationship, including the covered entity's level of control over the vendor's conduct.
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