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K&L Gates Triage: HIPAA: Do Hospitals Need a Business Associate Agreement with their Health System Parent Corporation?

Date: 20 August 2020

In this week’s episode, Rebecca Schaefer and Hannah Maroney discuss a string of recent HIPAA enforcement actions which demonstrate that the HHS Office of Civil Rights, the agency tasked with enforcing HIPAA, is increasingly focused on ensuring that affiliated hospitals within a health system, typically comprising an Affiliated Covered Entity (ACE), have HIPAA business associate agreements in place with the parent corporation to allow for the lawful exchange of PHI. The presenters discuss the circumstances in which a business associate agreement may be required, and address several questions regarding related ACE organizational considerations.

About Triage
Triage: Rapid Legal Lessons for Busy Health Care Professionals is a podcast created by the K&L Gates health care practice group to inform our clients and friends of the firm about the latest developments in health law. The K&L Gates Health Care practice will regularly create Triage podcasts to help you learn about the latest developments in health law. Our lawyers will identify the most important changes and analyze the impact of these changes on our clients. If you have feedback or would like to suggest a topic for a future episode, please contact us.

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Rebecca M. Schaefer
Rebecca M. Schaefer
Research Triangle Park
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Hannah C. Maroney
Hannah C. Maroney
Research Triangle Park
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