Please note that September 23, 2014
– an important compliance deadline – looms on the horizon for those BAA which
were “grandfathered” by HHS under the Final Rule because the BAA (1) existed
prior to January 25, 2013, (2) complied with the original BAA requirements set
out in 45 CFR 164.503(e), and (3) were not otherwise renewed or modified since
September 23, 2013, the Final Rule’s original compliance deadline.
Therefore, we urge all HIPAA covered
entities and business associates to make every effort to update these BAA to
incorporate the new Final Rule requirements on or before the September
23, 2014 compliance deadline. If you have any questions or
require assistance with these matters, please contact Meghan McNab at mmcnab@kdlegal.com
or Susan Ziel at sziel@kdlegal.com.