> I work at a university, and (newly) manage medical records from HIPAA
> covered entities. I was wondering whether or not the records center or RM
> program is considered a business associate or not. I did look through the
> list archives a bit and saw some rumblings about records centers as
> business
> associates, but I am having trouble seeing it that way. At least, not
> according to HHS guidance on their web site:
>
>
> http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/businessassociates.html
>
> Would anyone be able to clear things up a bit for me?
>
>
If the record center/RM Program is part of the University and its hospital
and it stores records as an administrative function for them, then no they
are not a "business associate".  If however the record center bills back
and charges for storage of records and providing access to them, then yes,
you could potentially be considered a business associate.

Larry
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-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*

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