Business Procedures Manual

Fiscal Affairs Division

26.4 Identification and Documentation of the HCC and Business Associate Relationships

(Last Modified on November 14, 2019)

The USO and each Institution are expected to have a document that either:

  • Identifies the portions of that Institution that are part of ¶¶ÒõÉçÇø¶ÌÊÓƵ’s HCC; or
  • Identifies business associate activities or services provided to another component of ¶¶ÒõÉçÇø¶ÌÊÓƵ that engages in covered functions as those terms are defined by HIPAA.

If the USO or a ¶¶ÒõÉçÇø¶ÌÊÓƵ Institution does contain a portion of the HCC, those HCC components shall be specifically described and identified in this documentation. Documentation should be maintained in the Legal Office of the USO and in an appropriate designated office at each ¶¶ÒõÉçÇø¶ÌÊÓƵ Institution. This documentation shall be reviewed and updated in January of each year.

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