The newly proposed rule to strengthen the HIPAA privacy and security rules imposes on subcontractors to business associates the same responsibilities--and liabilities--of business associates in securing the integrity and confidentiality protected health information.

This is a big deal, says Kate Borten, president of the Marblehead Group, a Massachusetts-based health information security consultancy. If the proposed language stays in the final rule, then the "chain of trust" between organizations handling PHI, envisioned in the HIPAA security rule when first proposed in 1998, finally will be in place, she contends.

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