BAA - Covered Entity and By missing values

Even though I have all the BAA fields filled out, these 2 fields are blank on the BAA. What am I doing wrong?


Hi Keith,

I see what you mean. It kind of does seem there is information missing there. But it’s actually all there and legally in tact. The “Covered Entity:” line is just the heading for the information that comes next. In other words, it’s saying this is the information for the covered entity, which is identified in the first paragraph of the document. Then, the “By:” is just introducing the person representing the covered entity and that person’s signature. And while has a fancy signature there, your e-signature is legally adequate.

Thank you for checking though. We appreciate you reaching out. I hope this response addresses your concern.

The previous BAA, per my example, shows the company. The BAA needs to be with the company, the individual is a representative of the company, so the BAA needs to show both the company name and the provider name, which the old BAA used to do.

You are correct in that the BAA is with the company. And the company must be listed on the BAA agreement. I shared your concern with our legal counsel who assured me that having the company specified in the recital (top of agreement) and then referenced as covered entity in the signature block is adequate. It is also important to note that the person signing the BAA must have authorization to sign on behalf of the company.

The previous BAA was also adequate, but it contained a lot of fields that were not necessary and were in fact confusing to many providers. Thus, we updated it to provide an experience that is both easy and adequate. I hope this answers your question.