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The BAA – How to Do It Right!

In this series, I have already shared four ways healthcare leaders can verify their compliance program is safe, which leads to:

#5: Implement and monitor Business Associate Agreements (BAAs).

Friends, don’t be like your colleagues that were hit with a $31,000 fine due to a lack of a business associate agreement.

The government knows mistakes will happen, but forgetting to sign a contract is not a mistake; that is negligence!

My wishful thinking can only hope you double-check your paperwork to ensure there are clear guidelines with your business associates.

So, if a breach occurs, it shows that your top priority is protecting PHI inside and outside the practice.

And, speaking of breaches, ensure your compliance program:

#6: Promotes a basic understanding of key enforcement laws.

As a leader, you must first acknowledge the government’s laws.

It is easy to say, “We didn’t know.” But unfortunately, the government will not buy that excuse.

The OIG recommends creating policies and procedures to ensure the entire practice complies with key enforcement laws.

It is not expected that one understands every healthcare law, but it is critical the entire practice can recognize an issue to prevent breaking the law.

Here are a few enforcement laws you can review to get you started:

  • False Claims Act
  • Anti-Kickback Statute
  • Physician Self-Referral Law (Stark Law)
  • Exclusion Authorities
  • Civil Monetary Penalties Law 

Stay current about the laws affecting your practice. Now is the time to connect with attorneys, consultants, or healthcare compliance associations to help you understand how these laws apply.

They can provide numerous examples of how it’s possible to break the law and the correct way to avoid it.

Consider building a relationship now, not when the government is knocking at your door.


*The opinions and observations from Joi Sherrod/group are not a promise to exempt your practice from fines and penalties.  Research, modify and tailor the advice to fit your specialty.

**Click here for the next tip in the series.

Joi Sherrod, MPH, CPC, CPCO
Joi Sherrod, MPH, CPC, CPCO
Joi is an educator and owner of JNC Healthcare Compliance Group. After working for distinguished academic teaching hospitals and clinics, she is passionate about helping medical, dental, and behavioral health practices rethink healthcare compliance one trend at a time. Contact Joi at