Developers and HIPAA

When are end-user disclosures to a subcontractor not incidental?

I'm a compliance consultant for early stage startups with tight budgets. I'm not sure how to advise them regarding BAAs for third-party services such as customer support ticketing that aren't meant to collect PHI, but may incidentally. (E.g. "[Covered entity] entered my profile information wrong and I don't know how to change it. It should say...") These subcontractors meet the NIST definition of a cloud service provider, ...more »

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Who are your customers? Check all that apply : Business associates (operates on behalf of/provides service to health care provider/health plan, e.g., an EHR vendor)

What is your organization? : Attorney/other compliance consultant

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