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No Business Associate Agreement? $31K Mistake

No Business Associate Agreement? $31K Mistake

The Center for Children’s Digestive Health (CCDH) has paid the U.S. Department of Health and Human Services (HHS) $31,000 to settle potential violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule and agreed to implement a corrective action plan. CCDH is a small, for-profit health care provider with a pediatric subspecialty practice that operates its practice in seven clinic locations in Illinois.

In August 2015, the HHS Office for Civil Rights (OCR) initiated a compliance review of the Center for Children’s Digestive Health (CCDH) following an initiation of an investigation of a business associate, FileFax, Inc., which stored records containing protected health information (PHI) for CCDH. While CCDH began disclosing PHI to Filefax in 2003, neither party could produce a signed Business Associate Agreement (BAA) prior to Oct. 12, 2015.

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About the Author: Jeff Robertson, ACMPE

Jeff Robertson, ACMPE
A passion for Healthcare is the best way to describe Jeff Robertson. He has a unique, varied and extensive background in Healthcare that covers a wide array of experience encompassing 22 years. Jeff is board certified by the American College of Medical Practice Executives to be a Practice Manager and is a proud member of MGMA. Jeff is also a member of HBMA and continues to keep his knowledge current and focused on future trends and initiatives and how they affect our Healthcare system. He has been actively running the Revenue Cycle Management and Practice Management divisions since 1999. Jeff has spent over 18 of the last 22 years in Outpatient Physician Clinics with a special focus on Healthcare IT, Revenue Cycle and Workflow Analysis. His passion and love of teaching, consulting and finding a better, more efficient way to build processes into a clinic has led to him being labeled the “Practice Fixer”.