HomeMy WebLinkAboutBackup DocumentHIPAA DATA SHARING AGREEMENT
This Business Associate Agreement ("Agreement") is entered into by and between Miami -
Dade County, a political subdivision of the State of Florida, (hereinafter "Covered Entity"), and
its agents or assignees, and the City of Miami, by and through its Department of Community and
Economic Development and its Housing Opportunities for Persons with AIDS (HOP WA) program
and its agents or assignees (hereinafter "Business Associate"), for purposes of complying with the
requirements of the Health Insurance Portability and Accountability Act of 1996 ("HIPAA").
RECITALS
A. Covered Entity wishes to disclose certain information ("Information") to Business
Associate some of which may constitute Protected Health Information ("PHI"), for the purpose of
coordinating care along the HIV Housing and Care and Treatment Continuums of Care.
B. Covered Entity and Business Associate intend to protect the privacy and provide
for the security of PHI disclosed to Business Associate in compliance with HIPAA and regulations
promulgated thereunder by the U.S. Department of Health and Human Services (the "HIPAA
Regulations") and other applicable laws.
In consideration of the mutual promises below and the exchange of information pursuant
to this Agreement, the parties agree as follows:
1. Definitions.
a) "Business Associate" shalI have the meaning given to such term under the HIPAA
Regulations, including, but not limited to, 45 CFR Section 160.103.
b) "Covered Entity" shall have the meaning given to such term under the HIPAA
Regulations, including, but not limited to, 45 CFR Section 160.103.
C) "Effective Date" shall mean the date that this Agreement is fully executed by the
parties.
d) "Individual" shall have the same meaning as the term "individual" in 45 CFR
164.501 and shall include a person who qualifies as a personal representative in accordance with
45 CFR 164.502(g).
e) "Protected Health Information" or "PHI" means any information, whether oral or
recorded in any form or medium: (i) that relates to the past, present or future physical or mental
condition of an individual; the provision of health care to an individual; or the past, present or
future payment for the provision of health care to an individual, and (ii) that identifies the
individual or with respect to which there is a reasonable basis to believe the information can be
used to identify the individual, and shall have the meaning given to such term under HIPAA and
the HIPAA Regulations, including, but not limited to 45 CFR Section 164.501.
2. Obligations and Activities of Business Associate.
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a) Business Associate agrees to not use or further disclosure Protected Health
Information other than as permitted or required by the Agreement or as required by law.
b) Business Associate agrees to use appropriate safeguards to prevent use or disclosure
of the Protected Health Information other than as provided for by this Agreement.
C) Business Associate agrees to report to Covered Entity any use or disclosure of the
Protected Health Information not provided for by this Agreement.
d) Business Associate agrees to ensure that any agent, including a subcontractor, to
whom it provides Protected Health Information received from, or created or received by Business
Associate on behalf of Covered Entity, agrees to these same restrictions and conditions.
e) Business Associate agrees to make internal practices, books, and records relating
to the use and disclosure of Protected Health Information received from, or created or received by
Business Associate on behalf of Covered Entity available to the Covered Entity, or at the request
of the Covered Entity, in a time and manner designated by the Covered Entity for purpose of the
Covered Entity's compliance with the Privacy Rule.
f) Business Associate agrees to document disclosures of Protected Health Information
and information related to such disclosures as would be required for Covered Entity to respond to
a request by an Individual for an accounting of disclosures of Protected Health Information.
g) Business Associate agrees to provide to Covered Entity as disclosure of Protected
Health Information occurs information collected in accordance with Section (f) of this Agreement,
to permit Covered Entity to respond to a request by an Individual for an accounting of disclosures
of Protected Health Information.
3. Obligations and Activities of Covered Entity.
a) Covered Entity shall provide Business Associate with notice of privacy practices
that Covered Entity produces in accordance with 45 CFR 164.520, as well as any changes to such
notice.
b) Covered Entity agrees to not use or further disclose Protected Health Information
received from Business Associate other than as permitted or required by the Agreement or as
required by law.
C) Covered Entity agrees to use appropriate safeguards to prevent use or disclosure of
the Protected Health Information received from Business Entity other than as provided for by this
Agreement.
d) Covered Entity agrees to report to Business Associate any use or disclosure of the
Protected Health Information not provided for by this Agreement.
e) Covered Entity agrees to ensure that any agent, including a subcontractor, to whom
it provides Protected Health Information received from, or created or received by Covered Entity
on behalf of Business Associate, agrees to the same restrictions and conditions.
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f) Covered Entity agrees to make internal practices, books, and records relating to the
use and disclosure of Protected Health Information received from, or created or received by
Covered Entity on behalf of Business Associate available to the Business Associate in a timely
manner designated by the Business Associate for purposes of the Covered Entity determining
Business Associate's compliance with the Privacy Rule.
g) Covered Entity agrees to document disclosures of Protected Health Information and
information related to such disclosures as would be required for Business Associate to respond to
a request by an individual for an accounting of disclosures of Protected Health Information.
h) Covered Entity agrees to provide to Business Associate as disclosures of Protected
Health Information occurs information collected in accordance with Section (f) of this Agreement,
to permit Business Associate to respond to a request by an Individual for an accounting of
disclosures of Protected Health Information.
4. Permissible Requests by Covered Entity or Business Associate.
a) Covered Entity shall not request Business Associate to use or disclose Protected
Health Information in any manner that would not be permissible under the Privacy Rule if done
by Covered Entity.
b) Business Associate shall not request Covered Entity Business Associate to use or
disclose Protected Health Information in any manner that would not be permissible under the
Privacy Rule if done by Business Associate.
5. Term
This agreement shall become effective on the Effective Date and shall continue in effect until all
obligations of the parties have been met, unless terminated as provided herein or by mutual
agreement of the parties.
6. Termination.
a) Material Breach. A breach by Business Associate of any material provision of
the Agreement, as determined by Covered Entity, shall constitute a material breach of the
Agreement and shall provide grounds for immediate termination of the Agreement by Covered
entity.
b) Reasonable Steps to Cure Breach. If Covered Entity knows of a pattern of
activity or practice of Business Associate that constitutes a material breach or violation of the
Business Associate's obligations under the provisions of this Agreement and does not terminate
this Agreement pursuant to Section 6(a), then Covered Entity shall take reasonable steps to cure
such breach or end such violation, as applicable. If Covered Entity's efforts to cure such breach
or end such violation are unsuccessful, Covered Entity shall either (i) terminate this Agreement, if
feasible or (ii) if termination of this Agreement is not feasible, Covered Entity shall report Business
Associate's breach or violation to the Secretary of the Department of Health and Human Services.
C) Judicial or Administrative Proceedings. The Covered Entity may terminate
this Agreement, effective immediately, if (i) the Business Associate is named as a defendant in a
criminal proceeding for a violation of HIPAA or (ii) a finding or stipulation that the Business
Associate has violated any standard or requirement of HIPAA or other security or privacy laws
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and is made in any administrative or civil proceeding in which the Business Associate has been
joined.
d) Effect of Tern-unation. Upon termination of this Agreement for any reason,
Business Associate shall return or destroy all Protected Health Information received from Covered
Entity, or created or received by Business Associate on behalf of Covered Entity, that Business
Associate still maintains in any form, and shall retain no copies of such PHI or, if return or
destruction is not feasible, it shall continue to extend the protections of the Agreement to such
information, and limit further use of such PHI to those purposes that make the return or destruction
of such PHI indefeasible. This provision shall apply to Protected Health Information that is in the
possession of subcontractors or agents of Business Associate.
7. Indemnification.
a) The Covered Entity shall indemnify and hold harmless the Business Associate, and
its officers, employees, agents, servants, agencies and instrumentalities from any and all liability,
losses or damages, including attorneys' fees and costs of defense, which the Business Associate
and its officers, employees, agents, servants, agencies or instrumentalities may incur as a result of
any and all claims, demands, suits, causes of action or proceedings of any kind or nature arising
out of, relating to or resulting from the performance of this Agreement by the Covered Entity or
the Covered Entity's officers, employees, agents, servants, partners, principals or subcontractors.
The Covered Entity shall pay all claims and losses of any kind in connection therewith and shall
investigate and defend all claims, suits or actions of any kind or nature in the name of the Business
Associate, where applicable, including appellate proceedings, and shall pay all costs, judgments,
and attorney's fees which may issue thereon. Provided, however, this indemnification shall only
be to the extent and within the limitations of Section 768.28 Florida Statutes, subject to the
provisions of that statute whereby the Covered Entity shall not be held liable to pay a personal
injury or property damage claim or judgment by any one person which exceeds the sum of
$200,000, or any claim or judgment or portions thereof, which, when totaled with all other claims
or judgments paid by the Covered Entity arising out of the same incident or occurrence, exceed
the sum of $300,000 from any and all personal injury or property damage claims, liabilities, losses
or causes of action which may arise as a result of the negligence of the Covered Entity or the
Covered Entity's officers, employees, servants, agents, partners, principals or subcontractors.
b) The Business Associate shall indemnify and hold harmless the Covered Entity, and
its officers, employees, agents, servants, agencies and instrumentalities from any and all liability,
losses or damages, including attorneys' fees and costs of defense, which the Covered Entity and
its officers, employees, agents, servants, agencies or instrumentalities may incur as a result of any
and all claims, demands, suits, causes of action or proceedings of any kind or nature arising out of,
relating to or resulting from the performance of this Agreement by the Business Associate or the
Business Associate's officers, employees, agents, servants, partners, principals or subcontractors.
The Business Associate shall pay all claims and losses of any kind in connection therewith and
shall investigate and defend all claims, suits or actions of any kind or nature in the name of the
Covered Entity, where applicable, including appellate proceedings, and shall pay all costs,
judgments, and attorney's fees which may issue thereon. Provided, however, this indemnification
shall only be to the extent and within the limitations of Section 768.28 Florida Statutes, subject to
the provisions of that statute whereby the Business Associate shall not be held liable to pay a
personal injury or property damage claim or Judgment by any one person which exceeds the sum
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of $200,000, or any claim or judgment or portions thereof, which, when totaled with all other
claims or judgments paid by the Business Associate arising out of the same incident or occurrence,
exceed the sum of $300,000 from any and all personal injury or property damage claims, liabilities,
losses or causes of action which may arise as a result of the negligence of the Business Associate
or the Business Associate's officers, employees, servants, agents, partners, principals or
subcontractors.
C) Term of Indemnification. The provisions of section (7) shall survive the
expiration or termination of this Agreement.
8. Survival. The respective rights and obligations of the Business Associate and the
Covered Entity shall survive the termination of this Agreement indefinitely.
9. Amendment. This Agreement may not be modified or amended, except in writing as
agreed to by both parties hereto.
10. No Third Party Beneficiaries. Nothing expressed or implied in this Agreement is intended
to confer, nor shall anything herein confer, upon any person other than the parties hereto, any
rights, remedies, obligations, or liabilities whatsoever.
11. Effect on Agreement. Except as specifically required to implement the purposes of this
Agreement, or to the extent inconsistent with this Agreement, all other terms of the Agreement
shall remain in force and effect.
12. Interpretation. This Agreement shall be interpreted as broadly as necessary to implement
and comply with HIPAA, HIPAA Regulations and applicable state laws.
13. Law. This Agreement shall be governed under the laws of the State of Florida as to all
matters, including but not limited to matters of validity, construction, effect and performance.
Venue for any Iitigation between parties regarding this Agreement shall lie only in state and federal
court in Miami -Dade County, Florida.
IN WITNESS WHEREOF, the parties have caused this Contract to be executed by their
respective and duly authorized officers as of the day and year first above written.
[SIGNATURES APPEAR ON THE FOLLOWING PAGES]
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For the City:
ATTEST:
Daniel J. Alfonso
City Manager
Date:
Victoria M6ndez
City Attorney
Todd B. Hannon
City Clerk
Ann -Marie Sharpe, Director
Department of Risk Management
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FOR MIAMI-DADE COUNTY, FLORIDA
ATTEST:
HARVEY RUVIN, CLERK MIAMI-DADE COUNTY, FLORIDA
Deputy Clerk
Approved as to form and legal sufficiency:
Terrence A. Smith
Assistant County Attorney
M.
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Mayor or Deputy Mayor