The blind spot of the business associate agreement

By Jay P. Anstine

Jay P. Anstine (Jay.anstine@bannerhealth.com) is the Area Compliance Program Director for Banner Health’s Western Division Rural Hospitals.

In looking at some of the notable Department of Health and Human Services, Office for Civil Rights (OCR) settlements this past year, one trend is emerging: Covered entities failing to have a business associates agreement (BAA) in place. Three such examples are Advanced Care Hospitalists (ACH),[1] Pagosa Springs Medical Center (PSMC),[2] and Cottage Health.[3]

ACH settlement

In September of 2018, the OCR settled with this physician practice for $500,000 related to a breach involving information viewable on a contracted billing provider’s website. The OCR’s investigation identified that ACH never executed a BAA with the billing company.

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