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.

By Jeff Robertson, ACMPE| October 20th, 2017| Practice Management, Medical Practice, shareholder, Uncategorized, Business Associate Agreement, medical billing, physician practice | 1 Comment

About the Author: 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 25 years. Jeff is board certified by the MGMA as a Medical Practice Executive and is a proud active member of MGMA. Jeff is also an active member of the Healthcare Business Management Association (HBMA) and continues to keep his knowledge current and focused on future trends and initiatives and how they affect our clients and their Clinic. Jeff has been actively running the Revenue Cycle Management and Practice Management divisions since 1997. Jeff Robertson has spent over 21 of the last 25 years in Independent Physician Clinics with a special focus on Medical Billing/Revenue Cycle Management, Healthcare IT, Clinical Workflow Analysis and Bookkeeping and Financials for Independent Medical Practices. 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”. To date, he has installed, configured, trained and consulted over 400 Independent Physician Clinics across the country and has learned valuable lessons from each of them to share with all of future clients.