Business Associate Agreement Policy (UBIT HIPAA)

Category: HIPAA Security
Responsible Office: UBIT HIPAA Compliance
Responsible Executive: Vice President and Chief Information Officer (VPCIO)
Approved By (Name/Title): J. Brice Bible, VPCIO

CATEGORY: Administrative Safeguards
TYPE: Standard
CITATION: 45 CFR 164.308(b)(1)

The University at Buffalo Information Technology (UBIT) operates as a covered entity as defined by the U.S. Department of Health and Human Services Office of Civil Rights. HIPAA Regulation Text 45 CFR 164.308(b)(1) requires a covered entity, in accordance with §164.306 Security Standard: General Rules, to permit a business associate to create, receive, maintain, or transmit ePHI on the covered entity’s behalf, only if the covered entity obtains satisfactory assurances, in accordance with §164.314(a) Business Associate Contracts and Other Arrangements that the business associate will appropriately safeguard the information.

UBIT permits a business associate to create, receive, maintain, or transmit ePHI on its behalf, only if the UBIT obtains satisfactory assurances, in accordance with its Business Associate Contracts or Other Arrangements Policy, that the business associate will appropriately safeguard the information.

This policy applies to all UBIT workforce members.

Workforce members: Adhere to all policies and procedures as written.

HIPAA Security and Privacy Officer: Assists the Compliance Officer in determining when UBIT systems and services require a BAA.

Compliance Officer: In conjunction with the HIPAA Security and Privacy Officer, the Compliance Officer ensures that business associate have signed a business associate contract with UBIT prior to creating, receiving, maintaining, or transmitting ePHI on its behalf.

Date Approved: 12/6/2017