Does your organization update its HIPAA business associate agreements to reflect recent changes? Does it conduct comprehensive risk assessments of vendors?

If not, how do you know if a vendor holding your data is updating its privacy practices, or is giving patients electronic copies of their medical records when requested, or understands how to handle requests to segregate sensitive treatment that was paid for out-of pocket? And how do you know if a vendor has appropriate access control and is encrypting your data?

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