First Healthcare Compliance CONNECT September 2019
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Client FAQ Corner<br />
Are healthcare providers required to provide HIPAA training to<br />
independent contractors?<br />
If the individual is not part of the provider’s workforce and they perform certain<br />
functions or activities that involve the use or disclosure of protected health information<br />
on behalf of, or provides services to, the provider, then they are a business associate.<br />
Workforce is defined as employees, volunteers, trainees, and other persons whose<br />
conduct, in the performance of work for a covered entity (provider) or business<br />
associate, is under the direct control of such covered entity or business associate,<br />
whether or not they are paid by the covered entity or business associate.<br />
It is common to overlook a business associate who has been working in your<br />
organization for a long period of time. If the individual is an independent contractor,<br />
issued a 1099 form, and performs functions that involve PHI, he/she must sign a<br />
Business Associate Agreement. And not doing so can be costly. Every time a business<br />
associate accesses your patients’ information without the proper agreement, your<br />
organization is potentially exposed to very large fines stemming from noncompliance<br />
with the HIPAA Privacy Rule. Equally important is hiring independant contractors that<br />
are aware of their HIPAA requirements. If they have not participated in an annual<br />
HIPAA training program, then it is best to assign these individuals training from our<br />
system.<br />
Explore the FAQs tab in your compliance solution to find<br />
answers to your compliance questions!<br />
Contact Toll Free: 888-54-FIRST 5
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