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a common question we receive at PCI HIPAA is who is considered a business associate here are three questions to help you determine who is a business associate first do they require disclosure of protected health information phi2 provide their services second are they your employee and finally are they a covered entity or someone who is only working with you to treat patients if you answered yes to question number one and no two questions two and three then they are most likely a business associate for example lawyers accountants consultants practice management software companies medical transcribers and third party administrators are all business associates they all are required to handle pH I to perform their services under HIPAA a covered entity and their business associates are required to enter into contracts called business associate agreements the agreement must describe the permitted uses of pH I state that the business associate will not use the pH I other than what is permitte

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