Business Associate agreement outline

As a service to our members, MGMA Government Affairs has developed this outline of a business associate agreement (BAA) in consultation with its Washington Counsel, Powers Pyles Sutter & Verville, PC. The outline is based in large part on sample provisions provided by the Department of Health and Human Services Office for Civil Rights (“OCR”) and available at http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/contractprov.html. At certain points throughout the outline, direct reference is made to OCR guidance.