Question

Linda codes medical records for a physician clinic. The physician practice did not initiate a BAA with Linda. Is Linda a BA? Why or why not?

Answer 1

The physician practice did not initiate a business associate agreement (BAA) with Linda as she is not a business associate (BA). She cannot be considered as a BA because she does not come under HIPPA's definition of a business associate even though she is a medical coder who handles protected health information (PHI). Professionals or entities who are part of the workforce of a covered entity are not considered as business associates. Temporary employees, interns, volunteers, etc are not included under the definition of a BA even if they get paid by the covered entity.