It would depend if they "used or disclosed PHI" on your behalf. If they do, you need a BAA.
Hope that helps.

Deborah Campbell
Compliance Coordinator

Dominion Dental Services, Inc.
115 South Union Street, Suite 300
Alexandria, Virginia 22314

Phn: (703) 518-5000 ext. 3035
Fax: (703) 518-8849
Toll Free:  888-518-5338
Email: [EMAIL PROTECTED]

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-----Original Message-----
From: Beth Miller [mailto:[EMAIL PROTECTED]
Sent: Friday, February 21, 2003 2:00 PM
To: WEDI SNIP Privacy Workgroup List
Cc: Linda Leyva
Subject: Re: Need for Business Associate Agreements

Hello, everyone -
 
This is a variation on the question about the need for BAA's.  My agency anticipates beginning a new federal contract soon.  As part of our original proposal, we obtained letters of intent from various partners who would be working with us on the contract if we were awarded.  Now that we've been awarded, we're intending to develop Memorandums of Understanding with these agencies, but are now wondering if we need BAA's with them as well as or instead of MOU's.  My understanding, at this point, is that it would have to do with whether or not PHI is exchanged, handled, etc., between agencies and, if so, how.  What does everyone else think?

Beth Miller
Grant Writer
Tri-City Mental Health Center

 
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The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time.

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