Hello all,

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?

Thanks,

Ryan

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