Simplifying payments for psychologists and their clients

A “business associate” is a person or entity that performs certain functions or activities that involve the use or disclosure of protected health information on behalf of, or provides services to, a covered entity. Normally, these entities must have a Business Associate Contract stipulating their compliance with HIPAA’s Privacy Rule. However, some business types are exempt from this requirement, including financial institutions like AffiniPay.

“When a financial institution processes consumer-conducted financial transactions by debit, credit, or other payment card, clears checks, initiates or processes electronic funds transfers, or conducts any other activity that directly facilitates or effects the transfer of funds for payment for health care or health plan premiums. When it conducts these activities, the financial institution is providing its normal banking or other financial transaction services to its customers; it is not performing a function or activity for, or on behalf of, the covered entity.”

–HIPAA Privacy, 45 CFR 164.502(e), 164.504(e), 164.532(d) and (e)