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Key Compliance Actions for the New HIPAA Privacy Regulations
Epstein Becker Green Link to more items from this source
[Guidance Overview]
Feb. 19, 2013

"[I]n analyzing relationships with vendors to determine whether business associate covenants must be obtained, covered entities and 'intermediate' business associates should look beyond mere naming conventions and make determinations regarding whether the data transmission organization has more than 'random or infrequent' access to PHI. Conversely, the Omnibus Rule provides clarification on entities that do not qualify as business associates[.]"

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