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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, CMPE, FMC

Jeff Robertson, CMPE, FMC
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 30 years. Jeff is board-certified by the MGMA as a Medical Practice Executive (CMPE) and Financial Management Certified (FMC) and a proud active MGMA member. 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 Clinics. Jeff has been actively running the Revenue Cycle Management and Practice Management divisions since 1997. Jeff Robertson has spent over 27 years in Independent Physician Clinics with a special focus on Medical Billing/Revenue Cycle Management, Healthcare IT, Clinical Workflow Analysis, and Medical Bookkeeping and Financials for Independent Medical Practices. His passion for 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 future clients.