Having written a series of posts over the years addressing employment contracting from the physician perspective, one of our readers reached out to let us know that Nixon Law Group should, likewise, address physician/clinician employment contracting from the perspective of the healthcare employer. Considerations for Clinician Contracting – An Employer Perspective…
Caitlin Riccobono, Esq., Counsel at Nixon Law Group, develops these routine “Partners Pointers” for the Virginia-based healthcare organization Partners in Healthcare.
Topic: Business Associates of Business Associates
I was asked to address two main questions regarding a Business Associate that is a subcontractor of another Business Associate (we will call this a “Sub-BA”). First, to what extent is a Sub-BA permitted access to PHI? Second, what are the Sub-BA’s obligations with respect to safeguarding PHI?