When A Business Associate Is Also A Covered Entity

Law360, New York (August 2, 2012, 1:45 PM EDT) -- Valuable guidance for covered entities and business associates can be contained in the U.S. Department of Health and Human Services list of breaches of unsecured protected health information affecting 500 or more individuals ("list breaches"), especially within the brief summaries of the breach cases that the federal Office of Civil Rights has investigated and closed.

An example is list breach 265 ("LB 265"), which reported a theft of a laptop in Alaska from Trisha Elaine Cordova, a business associate of Catholic Social Services ("CSS"), the related covered entity, on Feb. 1, 2011. The laptop reportedly contained approximately 493 adoption home studies...

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