The September 22, 2014 deadline for all HIPAA Business Associate Agreements (BAAs) entered into before January 25, 2013 to be updated and modified to compliance with the HIPAA Omnibus/Final Rule and HIPAA/HITECH enhanced civil fine schedule of up to $1.5 million per section violation per year is 3 weeks away. All post-January 25, 2013 BAAs must already be compliant.
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Source : Owen D. K. Kurtin PLLC, Attorneys at Law
