Janitorial services

February 4, 2005

I'm starting a new practice. Do I need to get a business associate contract signed by my janitorial services vendor?

Q: I'm starting a new practice. Do I need to get a business associate contract signed by my janitorial services vendor?

A: No. Under HIPAA, a business associate is a person or entity that performs services on your behalf that involve the use of protected health information. Although a janitorial service may have some access to such information in the course of cleaning your office, this access isn't required for the service to do its job. But you should consider implementing office policies that ensure that janitors and other service personnel don't access information inappropriately. (For instance, require that patient charts be returned to their files rather than left out on desks or countertops.)