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HIPAA Settlements Highlight Importance of Business Associate Contracts
Thomson Reuters / EBIA 
Jan. 25, 2019
"To date, at least seven resolution agreements have resulted from a covered entity's failure to enter into, or update, business associate contracts. Recognizing when a service provider is a business associate is crucial. Once business associates are identified, covered entities should keep a detailed inventory of business associate contracts and make sure they are accessible and updated. Failure to terminate access has also caught OCR's attention -- leading, for example, to a $5.5 million settlement in February 2017[.]"
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