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Do physicians with hospital privileges have to enter into business associate contracts with the hospital?


No. The hospital and such physicians participate in what the HIPAA Privacy Rule defines as an organized health care arrangement (OHCA). Thus, they may use and disclose protected health information for the joint health care activities of the OHCA without entering into a business associate agreement.


Created 12/19/02


Content created by Office for Civil Rights (OCR)
Content last reviewed on July 26, 2013