Provided by:  Jennifer Kirschenbaum, Esq.

June 13, 2019





Does my cleaning company need to sign a Business Associate Agreement?  They are in our space unsupervised. 

Dr. K


Yes, absolutely.  The cleaning company should enter into a business associate agreement.  Their personnel are in the premises unsupervised, as you point out, and has access to all patient PHI.   If you do not have a basic BAA for use, you can get one from our forms page, here -  Any party with more than "incidental" access needs to sign a BAA. 

For a deeper dive on HIPAA and access to PHI, check out Tuesday's webinar (CONDUCTING AND IMPLEMENTING SECURITY RISK ASSESSMENT RECOMMENDATIONS)
available HERE