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Do You Have Business Associate Agreements with Every Required Party?
McGuireWoods 
[Guidance Overview] May 14, 2024 "It is critical for all entities who create, receive, maintain or transmit PHI to ensure they have [business associate agreements (BAAs)] in place. [Covered entities (CEs)] must ensure they have BAAs with all of their [business associates (BAs)]; BAs must ensure they have BAAs with CE customers and BA subcontractors; subcontractors also need to ensure they have BAAs in place with their BA customers (often known as sub-BAAs). All parties need to ensure their BAAs comply with the statutory requirements, at a minimum." |
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