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Ryan,

The answer is yes. The covered functions that are used to determine if an organization is a business associate are: create, maintain, transmit, and transport protected health information. If you perform any of these services, either for or on behalf of a covered entity, then you are a BA.
Contact me offline for more help with this.

www.thehipaaman.com.




Regards,



Tom Dumez, CHP, CHCS | President   
(616) 893-8243 | www.thehipaaman.com


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-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of Ryan Speer
Sent: Tuesday, January 22, 2013 2:52 PM
To: [log in to unmask]
Subject: records centers as HIPAA business associates?

Hello all,

I work at a university, and (newly) manage medical records from HIPAA covered entities. I was wondering whether or not the records center or RM program is considered a business associate or not. I did look through the list archives a bit and saw some rumblings about records centers as business associates, but I am having trouble seeing it that way. At least, not according to HHS guidance on their web site:

http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/businessassociates.html

Would anyone be able to clear things up a bit for me?

Thanks,

Ryan

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