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Business Associate Agreement (BAA)

This BUSINESS ASSOCIATE AGREEMENT ("BA Agreement") supplements and is made a part of the existing Services Agreement (the "Services Agreement") provided by SavvyClinician™, Inc. ("Business Associate" or "BA") to you ("Covered Entity" or "CE").

RECITALS

CE wishes to disclose certain information to BA pursuant to the terms of this BA Agreement, some of which may constitute Protected Health Information ("PHI") and/or electronic Protected Health Information ("e-PHI").

SavvyClinician™ provides a cloud-based therapy management platform supporting medical and school-based speech-language pathology and other therapy services, subject to HIPAA, HITECH, Texas HB 300, and FERPA regulations.

CE and BA intend to protect the privacy of PHI and e-PHI that may be disclosed to, or created, received, maintained, or transmitted by BA pursuant to the Services Agreement in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and regulations promulgated thereunder, as well as the Health Information Technology for Economic and Clinical Health Act (HITECH) and all other applicable laws, including those specific to the State of Texas and the Family Educational Rights and Privacy Act (FERPA).

The purpose of this BA Agreement is to satisfy certain standards and requirements of the HIPAA Privacy Rule, Security Rule, and Breach Notification Rule, as amended by subsequent regulations.

DEFINITIONS

Terms used, but not otherwise defined, in this BA Agreement shall have the same meaning as those terms in the HIPAA Rules. In the event of a conflict, HIPAA definitions shall control.

OBLIGATIONS AND ACTIVITIES OF BUSINESS ASSOCIATE

BA agrees to:

Compliance with Security Rule

BA will comply with the HIPAA Security Rule and use appropriate administrative, technical, and physical safeguards to protect the confidentiality, integrity, and availability of e-PHI created, received, maintained, or transmitted on CE's behalf.

Compliance with Privacy Rule

BA will comply with applicable standards of the Privacy Rule regarding PHI.

Nondisclosure

BA shall not use or disclose PHI except as permitted by this Agreement or as required by law.

Minimum Necessary Rule

BA will make reasonable efforts to limit use/disclosure of PHI to the minimum necessary to accomplish the intended purpose.

Mitigation of Harm

BA shall mitigate, to the extent practicable, any harmful effects of unauthorized use or disclosure of PHI.

Subcontractors

BA will ensure any subcontractors who handle PHI agree to the same restrictions and conditions required under this Agreement.

Access to PHI

BA shall provide access to PHI in a Designated Record Set when required by CE, in compliance with 45 CFR § 164.524.

Breach Notification

BA shall notify CE of any breach of unsecured PHI without unreasonable delay, no later than 30 days after discovery, including:

  • • Date of breach and discovery
  • • Description of PHI involved
  • • Individuals affected
  • • Mitigation actions taken

BA shall cooperate fully with CE in breach investigation and notification.

PERMITTED USES AND DISCLOSURES

BA may use or disclose PHI as follows:

  • • To perform services for CE as described in the Services Agreement.
  • • For BA's proper management and legal responsibilities.
  • • For data aggregation services related to CE's operations.
  • • As required by law or to report violations of law.

OBLIGATIONS OF COVERED ENTITY

CE shall:

  • • Notify BA of any limitations in its privacy practices or individual restrictions affecting PHI handling.
  • • Provide relevant authorizations or restrictions in writing.
  • • Comply with minimum necessary rules when sharing PHI with BA.

TERM AND TERMINATION

Term: This Agreement remains in effect until all PHI is returned or destroyed.

Termination for Cause: CE may terminate for material breach by BA.

Effect of Termination: Upon termination, BA must return or securely destroy all PHI, unless retention is required by law.

MISCELLANEOUS

Regulatory References: All HIPAA references shall apply as amended.

Amendment: The parties agree to amend this Agreement as necessary to comply with HIPAA or state law changes.

Survival: BA's obligations regarding PHI survive termination.

Interpretation: Any ambiguity shall be resolved to permit compliance with HIPAA and Texas HB 300.

Indemnification: Each party agrees to indemnify the other for violations of this Agreement, including reasonable attorney's fees.

FERPA & Educational Records: For school-based therapy services, BA acknowledges FERPA applicability. Parents or guardians seeking to correct or delete educational records will be directed to CE, who will notify BA for action within 21 days.

GOVERNING LAW

This Agreement shall be governed by and construed under the laws of the State of Texas and applicable federal law.

NOTICE

Notices must be delivered in writing to the following addresses:

SavvyClinician™, Inc.
1400 Preston Road, Suite 300
Plano, Texas 75093
Attention: Privacy Officer