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February 2013


Breaking Down the HIPAA Rule Changes: Part 2 of 5

Changes Affecting Who is a Business Associate and New Business Associate Obligations


Some of the most significant changes that were made by the final HIPAA omnibus rule, published on January 25, 2013, in the Federal Register (the Final Rule) relate to the expanded definition of HIPAA Business Associates (BAs) and newly imposed legal obligations on BAs. The Final Rule also included an expansion of the elements that are required to be included in Business Associate Agreements (BAAs). The purpose of this e-alert is to provide a comprehensive look at: (i) the expansion of, clarifications to, and explicit inclusion of certain entities in the definition of a BA; (ii) the direct liability that the Final Rule imposes on BAs for noncompliance; and (iii) the elements that the Final Rule requires be included in BAAs and the compliance dates related thereto.

[Click here to read the full e-Alert.]

SAVE THE DATE: As we previously mentioned, we will also be holding a webinar on the Final Rule on February 20, 2013. More information will be coming soon.




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