Business Associate Agreements and Addendums Procedures - Revision history

Mhurlocker: updated email

2023-07-26T21:05:29Z

updated email

← Older revision		Revision as of 16:05, July 26, 2023
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	== Additional Information==		== Additional Information==
	*[mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer]		*[mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer]
	*[mailto:~~jeffrey.miller~~@unmc.edu Assistant Vice Chancellor for Business and Finance]		*[mailto:mhrncirik@unmc.edu Assistant Vice Chancellor for Business and Finance]
	*UNMC Policy No. 8009, [[Contracts]].<br />		*UNMC Policy No. 8009, [[Contracts]].<br />
	<br />		<br />

	This page maintained by [mailto:dpanowic@unmc.edu dkp].		This page maintained by [mailto:dpanowic@unmc.edu dkp].

Dpanowic at 18:12, October 6, 2020

2020-10-06T18:12:16Z

← Older revision		Revision as of 13:12, October 6, 2020
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	== Procedure ==		== Procedure ==
	#Departments are required to complete a Business Associate Agreement or Business Associate Addendum whenever vendors provide services on behalf of UNMC and have access to protected health information.		#Departments are required to complete a Business Associate Agreement or Business Associate Addendum whenever vendors provide services on behalf of UNMC and have access to protected health information.
	#~~Healthcare~~ providers providing patient care are exempt from the requirement.		#Health care providers providing patient care are exempt from the requirement.
	#Business Associate Agreements and Addendums are required for all new or modified contracts for services.		#Business Associate Agreements and Addendums are required for all new or modified contracts for services.
	#Business Associate Addendums are utilized whenever a formal contract is in place for the services being provided. The Addendum reinforces the services that have been specified in the contract and outlines the protected health information.		#Business Associate Addendums are utilized whenever a formal contract is in place for the services being provided. The Addendum reinforces the services that have been specified in the contract and outlines the protected health information.

Dpanowic at 18:07, October 6, 2020

2020-10-06T18:07:52Z

← Older revision		Revision as of 13:07, October 6, 2020
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	</table>		</table>
	<br />		<br />
	[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Trial Fee Billing ~~Procedures~~]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[International ~~Research Policy~~]] \| [[Health Care Vendor Interactions]] \| [[~~Internal Audit~~]] \| [[~~Credit Hour Definition~~]]		[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[Disclosing Foreign Support and International Activities]] \| [[Health Care Vendor Interactions]] \| [[Credit Hour Definition]] \| [[Whistleblower]]<br />
	<br /><br />Revised Date: 08/25/17<br />		<br />Revised Date: 10/06/20<br />
	Reviewed Date: 08/25/17<br />		Reviewed Date: 10/06/20<br />

	<big>'''Business Associate Agreements and Addendum Procedures'''</big><br />		<big>'''Business Associate Agreements and Addendum Procedures'''</big><br />
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	#Procurement will maintain an original file of the Business Associate Agreement or Addendum and will maintain an electronic database that will exhibit a current listing of those vendors, the services they are providing, and if they have, in fact, completed an agreement.		#Procurement will maintain an original file of the Business Associate Agreement or Addendum and will maintain an electronic database that will exhibit a current listing of those vendors, the services they are providing, and if they have, in fact, completed an agreement.
	#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.		#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.
	#In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by ~~UNMC legal counsel~~. In these cases, Procurement will be notified of such request for exception and will submit it for the legal exception.		#All Business Associates are required to implement all HIPAA Security Rule Safeguards. In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by the University’s Office of the Vice President and General Counsel. In these cases, Procurement will be notified of such request for exception and will submit it for the legal exception.
	~~For additional information, please contact the~~ [mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer] ~~or the~~ [mailto:jeffrey.miller@unmc.edu Assistant Vice Chancellor for Business and Finance]~~, or see~~ UNMC Policy No. 8009, [[Contracts]].<br />		== Additional Information==
			*[mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer]
			*[mailto:jeffrey.miller@unmc.edu Assistant Vice Chancellor for Business and Finance]
			*UNMC Policy No. 8009, [[Contracts]].<br />
	<br />		<br />

	This page maintained by dkp.		This page maintained by [mailto:dpanowic@unmc.edu dkp].

Afaylor: /* Procedure */ removed http:// from mailto:

2020-09-09T15:33:10Z

Procedure: removed http:// from mailto:

← Older revision		Revision as of 10:33, September 9, 2020
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	#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.		#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.
	#In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by UNMC legal counsel. In these cases, Procurement will be notified of such request for exception and will submit it for the legal exception.		#In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by UNMC legal counsel. In these cases, Procurement will be notified of such request for exception and will submit it for the legal exception.
	For additional information, please contact the [~~http://~~mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer] or the [~~http://~~mailto:jeffrey.miller@unmc.edu Assistant Vice Chancellor for Business and Finance], or see UNMC Policy No. 8009, [[Contracts]].<br />		For additional information, please contact the [mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer] or the [mailto:jeffrey.miller@unmc.edu Assistant Vice Chancellor for Business and Finance], or see UNMC Policy No. 8009, [[Contracts]].<br />
	<br />		<br />

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Afaylor: /* Procedure */ change wlawlor@unmc.edu to jeffrey.miller@unmc.edu

2020-09-09T14:56:24Z

Procedure: change wlawlor@unmc.edu to jeffrey.miller@unmc.edu

← Older revision		Revision as of 09:56, September 9, 2020
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	#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.		#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.
	#In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by UNMC legal counsel. In these cases, Procurement will be notified of such request for exception and will submit it for the legal exception.		#In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by UNMC legal counsel. In these cases, Procurement will be notified of such request for exception and will submit it for the legal exception.
	For additional information, please contact the [http://mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer] or the [http://mailto:~~wlawlor~~@unmc.edu Assistant Vice Chancellor for Business and Finance], or see UNMC Policy No. 8009, [[Contracts]].<br />		For additional information, please contact the [http://mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer] or the [http://mailto:jeffrey.miller@unmc.edu Assistant Vice Chancellor for Business and Finance], or see UNMC Policy No. 8009, [[Contracts]].<br />
	<br />		<br />

	This page maintained by dkp.		This page maintained by dkp.

Dpanowic at 15:04, March 21, 2018

2018-03-21T15:04:20Z

← Older revision		Revision as of 10:04, March 21, 2018
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	[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Trial Fee Billing Procedures]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[International Research Policy]] \| [[Health Care Vendor Interactions]] \| [[Internal Audit]] \| [[Credit Hour Definition]]		[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Trial Fee Billing Procedures]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[International Research Policy]] \| [[Health Care Vendor Interactions]] \| [[Internal Audit]] \| [[Credit Hour Definition]]
	<br /><br />Revised Date: 08/25/17<br />		<br /><br />Revised Date: 08/25/17<br />
	Reviewed Date: 08/25/17 ~~DRAFT~~<br />		Reviewed Date: 08/25/17<br />

	<big>'''Business Associate Agreements and Addendum Procedures'''</big><br />		<big>'''Business Associate Agreements and Addendum Procedures'''</big><br />

Dpanowic at 20:59, August 25, 2017

2017-08-25T20:59:53Z

← Older revision		Revision as of 15:59, August 25, 2017
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	#Procurement will maintain an original file of the Business Associate Agreement or Addendum and will maintain an electronic database that will exhibit a current listing of those vendors, the services they are providing, and if they have, in fact, completed an agreement.		#Procurement will maintain an original file of the Business Associate Agreement or Addendum and will maintain an electronic database that will exhibit a current listing of those vendors, the services they are providing, and if they have, in fact, completed an agreement.
	#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.		#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.
	#In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by UNMC legal counsel. In these cases, ~~Purchasing~~ will be notified of such request for exception and will submit it for the legal exception.		#In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by UNMC legal counsel. In these cases, Procurement will be notified of such request for exception and will submit it for the legal exception.
	For additional information, please contact the [http://mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer] or the [http://mailto:wlawlor@unmc.edu Assistant Vice Chancellor for Business and Finance], or see UNMC Policy No. 8009, [[Contracts]].<br />		For additional information, please contact the [http://mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer] or the [http://mailto:wlawlor@unmc.edu Assistant Vice Chancellor for Business and Finance], or see UNMC Policy No. 8009, [[Contracts]].<br />
	<br />		<br />

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Dpanowic at 20:53, August 25, 2017

2017-08-25T20:53:56Z

← Older revision		Revision as of 15:53, August 25, 2017
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	Revised Date: 08/25/17<br />		<table style="background:#F8FCFF; text-align:center" width="100%" cellspacing="0" cellpadding="0" border="0">
			<tr>
			<td style="padding:0.5em; background-color:#e5e5e5; font-size:90%; line-height:0.95em; border:1px solid #A3B1BF; border-bottom:solid 2px #A3B1BF" width="20">[[Human Resources]]</td>
			<td style="border-bottom:2px solid #A3B1BF" width="3"> </td>
			<td style="padding:0.5em; background-color:#e5e5e5; font-size:90%; line-height:0.95em; border:1px solid #A3B1BF; border-bottom:solid 2px #A3B1BF" width="20">[[Safety/Security]] </td>
			<td style="border-bottom:2px solid #A3B1BF" width="3"> </td>
			<td style="padding:0.5em; background-color:#e5e5e5; font-size:90%; line-height:0.95em; border:1px solid #A3B1BF; border-bottom:solid 2px #A3B1BF" width="20">[[Research Compliance]] </td>
			<td style="border-bottom:2px solid #A3B1BF" width="3"> </td>
			<td style="padding:0.5em; background-color:white; line-height:0.95em; border:solid 2px #A3B1BF; border-bottom:0; font-weight:bold;" width="20">[[Compliance]]</td>
			<td style="border-bottom:2px solid #A3B1BF" width="3"> </td>
			<td style="padding:0.5em; background-color:#e5e5e5; font-size:90%; line-height:0.95em; border:1px solid #A3B1BF; border-bottom:solid 2px #A3B1BF" width="20">[[Privacy/Information Security]]</td>
			<td style="border-bottom:2px solid #A3B1BF" width="3"> </td>
			<td style="padding:0.5em; background-color:#e5e5e5; font-size:90%; line-height:0.95em; border:1px solid #A3B1BF; border-bottom:solid 2px #A3B1BF" width="20">[[Business Operations]]</td>
			<td style="border-bottom:2px solid #A3B1BF" width="3"> </td>
			<td style="padding:0.5em; background-color:#e5e5e5; font-size:90%; line-height:0.95em; border:1px solid #A3B1BF; border-bottom:solid 2px #A3B1BF" width="20">[[Intellectual Property]]</td>
			</tr>
			</table>
			<br />
			[[Compliance Program]] \| [[Compliance Hotline]] \| [[Investigations by Third Parties]] \| [[Research Integrity]] \| [[Export Control]] \| [[Code of Conduct]] \| [[Use of Human Anatomical Material]] \| [[Clinical Trial Fee Billing Procedures]] \| [[Contracts]] \| [[Conflict of Interest]] \| [[Red Flag Identity Theft Prevention Program]] \| [[Principles of Financial Stewardship]] \| [[Human Tissue Use and Transfer]] \| [[International Research Policy]] \| [[Health Care Vendor Interactions]] \| [[Internal Audit]] \| [[Credit Hour Definition]]
			<br /><br />Revised Date: 08/25/17<br />
	Reviewed Date: 08/25/17 DRAFT<br />		Reviewed Date: 08/25/17 DRAFT<br />

Dpanowic at 20:46, August 25, 2017

2017-08-25T20:46:12Z

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	#Business Associate Addendums are utilized whenever a formal contract is in place for the services being provided. The Addendum reinforces the services that have been specified in the contract and outlines the protected health information.		#Business Associate Addendums are utilized whenever a formal contract is in place for the services being provided. The Addendum reinforces the services that have been specified in the contract and outlines the protected health information.
	#Business Associate Agreements are required whenever services are being provided and a formal contract has not been executed. In this case the Business Associate Agreement will outline the services being provided and the protected health information available.		#Business Associate Agreements are required whenever services are being provided and a formal contract has not been executed. In this case the Business Associate Agreement will outline the services being provided and the protected health information available.
	#The Business Associate Agreements and Addendums are available electronically at [[https://www.unmc.edu/hipaa/forms/index.html]]. Although they are in Word format, they should not be changed in content. Only the parties to the agreement and the services being provided may be changed. These agreements can only be properly executed by the Procurement Department. Two copies should be prepared in order to provide the vendor with an original.		#The Business Associate Agreements and Addendums are available electronically at [https://www.unmc.edu/hipaa/forms/index.html https://www.unmc.edu/hipaa/forms/index.html]. Although they are in Word format, they should not be changed in content. Only the parties to the agreement and the services being provided may be changed. These agreements can only be properly executed by the Procurement Department. Two copies should be prepared in order to provide the vendor with an original.
	#Procurement will maintain an original file of the Business Associate Agreement or Addendum and will maintain an electronic database that will exhibit a current listing of those vendors, the services they are providing, and if they have, in fact, completed an agreement.		#Procurement will maintain an original file of the Business Associate Agreement or Addendum and will maintain an electronic database that will exhibit a current listing of those vendors, the services they are providing, and if they have, in fact, completed an agreement.
	#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.		#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.

Dpanowic at 20:44, August 25, 2017

2017-08-25T20:44:29Z

← Older revision		Revision as of 15:44, August 25, 2017
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	Revised Date: 12/19/06<br />		Revised Date: 08/25/17<br />
	Reviewed Date: 12/19/06<br />		Reviewed Date: 08/25/17 DRAFT<br />

	<big>'''Business Associate Agreements and Addendum Procedures'''</big><br />		<big>'''Business Associate Agreements and Addendum Procedures'''</big><br />
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	#Departments are required to complete a Business Associate Agreement or Business Associate Addendum whenever vendors provide services on behalf of UNMC and have access to protected health information.		#Departments are required to complete a Business Associate Agreement or Business Associate Addendum whenever vendors provide services on behalf of UNMC and have access to protected health information.
	#Healthcare providers providing patient care are exempt from the requirement.		#Healthcare providers providing patient care are exempt from the requirement.
	#Business Associate Agreements and Addendums are required for all new or modified contracts for services ~~after October 13, 2002. Existing contracts require Business Associate Agreements or Addendums by April 15, 2005~~.		#Business Associate Agreements and Addendums are required for all new or modified contracts for services.
	#Business Associate Addendums are utilized whenever a formal contract is in place for the services being provided. The Addendum reinforces the services that have been specified in the contract and outlines the protected health information.		#Business Associate Addendums are utilized whenever a formal contract is in place for the services being provided. The Addendum reinforces the services that have been specified in the contract and outlines the protected health information.
	#Business Associate Agreements are required whenever services are being provided and a formal contract has not been executed. In this case the Business Associate Agreement will outline the services being provided and the protected health information available.		#Business Associate Agreements are required whenever services are being provided and a formal contract has not been executed. In this case the Business Associate Agreement will outline the services being provided and the protected health information available.
	#The Business Associate Agreements and Addendums are electronically ~~on file in SLUGO under HIPAA~~. ~~They~~ are in ~~a PDF~~ format, ~~thus cannot~~ be changed in content. Only the parties to the agreement and the services being provided may be changed. These agreements can only be properly executed by the ~~Purchasing~~ Department. Two copies should be prepared in order to provide the vendor with an original.		#The Business Associate Agreements and Addendums are available electronically at [[https://www.unmc.edu/hipaa/forms/index.html]]. Although they are in Word format, they should not be changed in content. Only the parties to the agreement and the services being provided may be changed. These agreements can only be properly executed by the Procurement Department. Two copies should be prepared in order to provide the vendor with an original.
	#~~Purchasing~~ will maintain an original file of the Business Associate Agreement ~~and~~ or Addendum and will maintain an electronic database that will exhibit a current listing of those vendors, the services they are providing, and if they have, in fact, completed an agreement.		#Procurement will maintain an original file of the Business Associate Agreement or Addendum and will maintain an electronic database that will exhibit a current listing of those vendors, the services they are providing, and if they have, in fact, completed an agreement.
	#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.		#Only one Business Associate Agreement or Addendum is required by the University as long as the services to be performed remain constant. In the event that the vendor is providing more than one service, an additional agreement is required.
	#In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by UNMC legal counsel. In these cases, Purchasing will be notified of such request for exception and will submit it for the legal exception.		#In the event that a vendor cannot meet a specific requirement of the Business Associate Agreement or Addendum, i.e., insurance, etc., an exception can be granted only by UNMC legal counsel. In these cases, Purchasing will be notified of such request for exception and will submit it for the legal exception.
	For additional information, please contact the [http://mailto:~~swrobel~~@unmc.edu Compliance Officer] or the [http://mailto:~~kswarts~~@unmc.edu ~~Director,~~ Business ~~Services~~], or see UNMC Policy No. 8009, [[Contracts]].<br />		For additional information, please contact the [http://mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer] or the [http://mailto:wlawlor@unmc.edu Assistant Vice Chancellor for Business and Finance], or see UNMC Policy No. 8009, [[Contracts]].<br />
	<br />		<br />

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