In January 2013, the HIPAA Omnibus Final Rule was published in the Federal Register. While the initial compliance date for most components of the Final Rule was Sept. 23, 2014, Business Associate Agreements (BAAs) did not have to be updated until the existing agreement expired or by Sept. 22, 2015–the final compliance date. If providers have not already updated their existing Business Associate Agreements, they should start familiarizing themselves with the following before the Sept. 22 deadline:
- changes made to the definitions of business associates
- changes in liability
- changes in compliance obligations for business associates
- changes required in BAAs