OCRHIPAA Privacy Rule

HIPAA Business Associate Agreements (45 CFR 164.504(e))

Required contract elements for any business associate that creates, receives, maintains, or transmits PHI on behalf of a covered entity.

Primary source

45 CFR 164.504(e) — eCFR

https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.504#p-164.504(e)

Verified May 23, 2026 · This is the authoritative regulator URL. The summary below is a research aid; the linked source controls.

45 CFR 164.504(e)) requires a written contract between a covered entity and each business associate. Required terms include: permitted uses and disclosures, prohibition on impermissible use, required safeguards (including Security Rule compliance for ePHI), reporting of unauthorized uses and disclosures, ensuring subcontractor compliance via flow-down BAAs, individual access support, accounting support, amendment support, return or destruction at termination, and breach notification per 164.410.

Since HITECH (2009) and the 2013 Omnibus Rule, business associates are directly liable for Privacy Rule misuse and Security Rule failure. A missing or inadequate BAA is itself a Privacy Rule violation by the covered entity (cited in numerous OCR settlements).

OCR publishes sample BAA provisions to satisfy the regulatory requirements. The sample is a starting point — practices typically layer liability allocation, term, and operational provisions negotiated with counsel, appropriate to the vendor relationship and without weakening the regulatory minimums.

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Last reviewed May 23, 2026 · Citation verified May 23, 2026

Research aid, not legal advice. This summary is an administrative research aid prepared by D3rx. It does not certify compliance, provide legal advice, replace counsel, or guarantee an audit outcome. For authoritative regulatory text follow the primary source link at the top of this page. The practice remains responsible for reviewing, adopting, and maintaining its compliance program.