Deadline For Business Associate Agreement And Data Use Agreement Compliance Is September 22, 2014

September 22, 2014 is the deadline to have all business associate and data use agreements updated to conform to the new requirements of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Final Omnibus Rule (Omnibus Rule), which became effective September 23, 2013. Eligible business associate agreements and data use agreements are protected under the transition provisions of the Omnibus Rule until September 22, 2014.

On January 25, 2013, the US Department of Health and Human Services published the HIPAA Omnibus Rule, which includes a transition provision permitting a covered entity, or a business associate with respect to a subcontractor, to continue to create, receive, maintain or transmit protected health information in reliance on a business associate agreement that complies with the prior rules. A similar transition provision permits a covered entity to continue to transmit a limited data set to a recipient in reliance on a data use agreement that complies with the prior rules. The transition provisions allow covered entities and business associates to operate under the earlier agreements until September 22, 2014.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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