1.    Are you routinely adding business associate agreements or other HIPAA language to your outgoing subcontracts without regard to applicability for a particular subcontract?
 
2.    Have you seen business associate agreements or other HIPAA language in the subcontracts or privately funded contracts you receive?  If so, has the language been included only in those agreements where applicable or without regard to relevance? 
 
I realize that business associate agreements are not required for disclosures from a covered entity to a researcher for research purposes, however, we've started receiving some of these agreements.  The senders have indicated they want all of their subcontractors to enter into such agreements regardless of applicability.
 
Thanks in advance for any responses.
 
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Wendy Beaver                  
Associate Director
Sponsored Programs          Ph:  319-335-2122
2 Gilmore Hall
The University of Iowa          Fax:  319-335-2130
Iowa City, IA 52242
xxxxxx@uiowa.edu
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