Business Associate Agreements (BAAs) Policy

Date Approved 
Tuesday, Sept. 10, 2019

The HIPAA rules generally require that covered entities enter into contracts with their business associates to ensure that each party will appropriately safeguard protected health information. The business associate contract also serves to clarify and limit, as appropriate, the permissible uses and disclosures of protected health information by the business associate, based on the relationship between the parties and the activities or services being performed by the business associate.  A business associate may use or disclose protected health information only as permitted or required by its business associate contract or as required by law.

The scope of this policy is all workforce members of Pacific University’s health care component. Pacific University is a hybrid entity. Only the health care component (i.e., the covered functions) of Pacific University must comply with this policy. All references in this policy to “Pacific University” shall be construed to refer only to the health care component of Pacific University.

Business associate agreements must be in writing and must include terms authorized and approved by the Privacy Office and Legal Affairs, in order to maintain compliance with federal and state privacy regulations. When Pacific University enter into agreements with outside vendors involving the vendor’s access or exposure to information considered to be protected health information (PHI), pursuant to the Health Information Privacy and Portability Act (HIPAA), a BAA is required. 

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Supplemental Documents:

Business Associate Decision Tree
Business Associate FAQ
Business Associates Procedure Outline
Business Associate Agreement Template