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ARTICLE · 12 SEPTEMBER 2014

Business Associate Agreements May Require Amendment

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The Omnibus Final Rule under the HIPAA was issued in January, 2013 effective March 26, 2013, but with a general compliance deadline of September 23, 2013.

United StatesEmployment and HR
Jeffrey Ashendorf
Jeffrey Ashendorf
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The Omnibus Final Rule (the "Omnibus Rule") under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), was issued in January, 2013 effective March 26, 2013, but with a general compliance deadline of September 23, 2013. Compliance with the Omnibus Rule required changes to many HIPAA compliance practices and related documents, including business associate agreements, the HIPAA notice of privacy practices and breach assessment policies and procedures.

With respect to business associate agreements, however, the Omnibus Rule included transition relief that allowed certain health plans an extended transition period within which to make necessary changes to their business associate agreements if certain conditions were met.

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