The HIPAA spotlight is beginning to shine brightly on business associates. Covered entities have long had their time to star, so it is only fair to share the stage now. It is likely that covered entities are only too happy to have the Office for Civil Rights and others focus attention on business associates, with all the consequences that come with such attention.

A potentially non-punitive form of attention are the soon to begin desk audits of business associates. Recent statements from individuals in OCR, including Deputy Director for Health Information Privacy Deven McGraw, say that the desk audits are to begin this month. Unlike covered entities who received emails confirming information first, business associates will be thrown right into the response fire.

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