Agr HIPPA Business Associate AgreementBUSINESS ASSOCIATE AGREEMENT
Whereas, [CITY OF SALINA EMS 1(Business Associate)
Name of Contractor or other entity
will provide/provides certain services to the Department of Veterans Affairs (Covered
Entity), and, in connection with the provision of those services, the Covered Entity will
disclose/discloses to Business Associate Protected Health Information (PHI) and
Electronic Protected Health Information (EPHI) that is subject to protection under the
regulations issued by the Department of Health and Human Services, as mandated by
the Health Insurance Portability and Accountability Act of 1996 (HIPAA); 45 CFR Parts
160 and 164, Sub; arts A and E, the Stan6ards for Privacy of individually Identifiable
Health Information ("Privacy Rule"); and 45 CFR Parts 160 and 164, Subparts A and C,
the Security Standard ("Security Rule"); and
Whereas, VA is a "Covered Entity" as that term is defined in the HIPAA
implementing regulations, 45 CFR 160.103, and
Whereas, [CITY OF SALINA EMS j, as a recipient of PHI
Name of Business Associate
from Covered Entity, is a "Business Associate" of the Covered Entity as the term
"Business Associate" is defined in the HIPAA implementing regulations, 45 CFR
160.103; and
Whereas, pursuant to the Privacy and Security Rules, all Business Associates of
Covered Entities must agree in writing to certain mandatory provisions regarding the
use and disclosure of PHI and EPHI; and
Whereas, the purpose of this Agreement is to comply with the requirements of the
Privacy and Security Rules, including, but not limited to, the Business Associate
contract requirements ^t 45 C.F.R. §§164.308(b), 164.314(a), 164.502(e), and
164.504(e), and as may be amended.
NOW, THEREFORE, in consideration of the mutual promises and covenants
contained herein, the parties agree as follows:
1. Definitions. Unless otherwise provided in this Agreement, capitalized terms have
the same meanings as set forth in the Privacy and Security Rules. The term
"Protected Health Information" or the abbreviation "PHI" shall include the term
"Electronic Protected Health information" and the abbreviation "EPHI" in this
Agreement.
2. Ownership of PHI. PHI provided to Business Associate or created, gathered
or received by Business Associate, its agents and subcontractors under this
agreement is the property of Covered Entity.
3. Scope of Use and Disclosure by Business Associate of Protected Health
Information and Electronic Protected Health Information
A. Business Associate shall be permitted to make Use and Disclosure of PHI
that is disclosed to it by Covered Entity, or created, gathered or received
by Business Associate on behalf of Covered Entity, as necessary to
perform its obligations under this Agreement, and [CITY OF SALINA
Ems,
contractor number or agreement description
provided that the Covered Entity may make such Use or Disclosure under
the Privacy and Security Rules, and the Use or Disclosure complies with
the Covered Entity's minimum necessary policies and procedures .
B. Unless otherwise limited herein, in addition to any other Uses and/or
Disclosures permitted or authorized by this Agreement or required by law,
Business Associate may:
(1) use the PHI in its possession for its proper management and
administration and to fulfill any legal responsibilities of Business
Associate;
(2) make a Disclosure of the PHI in its possession to a third party for the
purpose of Business Associate's proper management and administration
or to fulfill any legal responsibilities of Business Associate; provided,
however, that the disclosures are Required By Law or permitted by
,24 Federal law and VA Policy and Business Associate has received from the
third party written assurances that (a) the information will be held
confidentially and Used or further Disclosure made only as Required By
Law or for the purposes for which it was disclosed to the third party; and
(b) the third party will notify the Business Associate of any instances of
which it becomes aware in which the confidentiality of the information has
been breached;
(3) engage in Data Aggregation activities, consistent with the Privacy
Rule; and
(4) de -identify any and all PHI created or received by Business Associate
under this Agreement; provided, that the de -identification conforms to the
requirements of the Privacy Rule.
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4. Obligations of Business Associate. In connection with its Use and Disclosure of
PHI received from Covered Entity or created, gathered or received on behalf of
Covered Entity, Business Associate agrees that it will:
A. Use or make further Disclosure of PHI only as permitted or required by this
Agreement or as Required By Law;
B. Use reasonable and appropriate safeguards to prevent Use or Disclosure of
PHI other than as provided for by this Agreement,-
C.
greement;
C. To the extent practicable, mitigate any harmful effect that is known to
Business Associate of a Use or Disclosure of PHI by Business Associate in
violation of this Agreement;
D. Promptly report to Covered Entity any Security Incident, or Use or
Disclosure of PHI not provided for by this Agreement, of which Business
Associate becomes aware;
E. Require contractors, subcontractors or agents to whom Business Associate
provides PHI to agree to the same restrictions and conditions that apply to
Business Associate pursuant to this Agreement, including implementation
of reasonable and appropriate safeguards to protect PHI;
F. Make available to the Secretary of Health and Human Services Business
Associate's internal practices, books and records, including policies and
procedures, relating to the Use or Disclosure of PHI for purposes of
determining Covered Entity's compliance with the Privacy and Security
Rules, subject to any applicable legal privileges;
G. If the Business Associate maintains PHI in a Designated Record Set,
maintain the information necessary to document the disclosures of PHI
sufficient to make an accounting of those disclosures as required under
the Privacy Rule and the Privacy Act, 5 USC 552a, and within (15) days of
receiving a request from Covered Entity, make available the information
necessary for Covered Entity to make an accounting of Disclosures of PHI
about an individual in the Designated Record Set or Covered Entity's
Privacy Act System of Records;
H. If the Business Associate maintains PHI in a Designated Record Set or
Privacy Act System of Records, within ten (10) days of receiving a written
request from Covered Entity, make available PHI in the Designated
Record Set or System of Records necessary for Covered Entity to
respond to individuals' requests for access to PHI about them that is not in
the possession of Covered Entity;
91
If the Business Associate maintains PHI in a Designated Record Set or
Privacy Act System of Records, within fifteen (15) days of receiving a
written request from Covered Entity, incorporate any amendments or
corrections to the PHI in the Designated Record Set or System or Records
in accordance with the Privacy Rule and Privacy Act;
J. Not make any Uses or Disclosures of PHI that Covered Entity would be
prohibited from making.
K. When Business Associate is uncertain whether it may make a particular Use
or Disclosure of PHI in performance of this Agreement and the underlying
agreement, the Business Associate will obtain the approval of the
Covered Entity before making the Use or Disclosure.
L. Implement administrative, physical, and technical safeguards that
reasonably and appropriately protect the confidentiality and integrity, and
availability of the PHI that Business Associate creates, receives,
maintains, or transmits on behalf of the Covered Entity as required by the
Security Rule.
M. Upon completion of the contract, the Business Associate shall return or
destroy the PHI gathered, created, received or processed during the
performance of this contract, and no data will be retained by the Business
Associate, and any agents and subcontractors of the Business Associate.
The Business Associate shall certify that all PHI has been returned to the
Covered Entity or destroyed. If immediate return or destruction of all data
is not possible, the Business Associate shall certify that all PHI retained
will be safeguarded to prevent unauthorized Uses or Disclosures. Until
the Business Associate has completed certification, Covered Entity
will withhold 15% of the final payment of the contract.
5. Obligations of Covered Entity. Covered Entity agrees that it:
A. Has obtained, and will obtain, from Individuals any consents,
authorizations and other permissions necessary or required by laws
applicable to Covered Entity for Business Associate and Covered Entity to
fulfill their obligations under this Agreement or the underlying agreement,
[CITY OF SALINA EMS 1;
describe agreement or enter contract number
B. Will promptly notify Business Associate in writing of any restrictions on the
Use and Disclosure of PHI about Individuals that Covered Entity has
agreed to that may affect Business Associate's ability to perform its
obligations under this Agreement;
C. Will promptly notify Business Associate in writing of any changes in, or
revocation of, permission by an Individual to use or disclose PHI, if such
n
changes or revocation may affect Business Associate's ability to perform
its obligations under this Agreement or the underlying agreement.
6. Termination.
A. Termination for Cause. Upon Covered Entity's knowledge of a material
breach by Business Associate, Covered Entity shall either:
(1) provide an opportunity for Business Associate to cure the breach or end
the violation and terminate this Agreement if Business Associate does not
cure the breach or end the violation within the time specified by Covered
Entity;
(2) immediately terminate this Agreement if Business Associate has breached
a material term of this Agreement and cure is not possible;
(3) if neither termination nor cure are feasible, Covered Entity shall report the
violation to the Secretary of Health and Human Services.
B. Automatic Termination. This Agreement will automatically terminate upon
completion of the Business Associate's duties under the underlying
agreement, or termination of that agreement by either party.
C. Effect of Termination.
(1) Termination of this Agreement will result in cessation of activities by the
Business Associate, and any agents or subcontractors of it involving PHI
under this Agreement and [CITY OF SALINA EMS j
Contract number or agreement description
(2) Upon termination of this Agreement, Business Associate will return or
destroy all PHI received from Covered Entity or created, gathered or
received by Business Associate and its agents and subcontractors on
behalf of Covered Entity under this Agreement. The Business Associate
shall certify that all PHI has been returned to Covered Entity or destroyed.
If immediate return or destruction of all PHI is not possible, the contractor
further certifies that any data retained will be safeguarded to prevent
unauthorized Uses or Disclosures.
7. Amendment. Business Associate and Covered Entity agree to take such action as
is necessary to amend this Agreement for Covered Entity to comply with the
requirements of the Privacy and Security Rules or other applicable law.
8. Survival. The obligations of Business Associate under section 6.C. (2) of this
Agreement shall survive any termination of this Agreement..
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9. No Third Party Beneficiaries. Nothing express or implied in this Agreement is
intended to confer, nor shall anything herein confer, upon any person other than
the parties and their respective successors or assigns, any rights, remedies,
obligations or liabilities whatsoever.
10.Other Applicable Law. This Agreement does not, and is not intended to, abrogate
any responsibilities of the parties under any other applicable law.
11.In the event terms and conditions differ, the terms and conditions of the contract
[CITY OF SALINA EMS ] shall take precedence.
Contract number or agreement description
12.Effective Date. This Agreement shall be effective on April 14, 2003.
City of SaIina FVR
VA 8siesie
By:
By:
Name:
JANET L. FORD
Name: 1j;b-dney Fra z
Title:
HIPPA Coordinator
Title: Director of finance
Date:
April 8, 2003
Date: Jkpril 17 2003
1
April 8, 2003
CITY OF SALINA EMS
P0BOX 736
SALINA , KS 67402-0736
DEPARTMENT OF VETERANS AFFAIRS
Robert J. Dole
Medical & Regional Office Center
5500 East Kellogg
Wichita KS 67218 f�
In Reply Refer To: 589A7/001 I
Reference: CITY OF g ALINA EMS
Your Organization has been identified as a Business Associate of the Department of Veterans
Affairs for the above Contract/Agreement, as defined in Health Insurance Portability and
Accountability Act (HIPPA), Public Law 104-191.
Please execute the enclosed Business Associate Agreement and return it to me by Close of
Business, April 15, 2003.
Execution of the Agreement will enable us to achieve compliance with HIPPA privacy and
security standards for the use and disclosure of protected health information to our Business
Associates.
Your cooperation in this matter is greatly appreciated.
If you have any questions regarding this matter, please contact Janet Ford at (316) 685-2221
ext. 3322.
Sincerely yours,
l.'. -' c4
JANET L. FORD
HIPPA Coordinator
Enclosure