Well, most of you have heard me, for several years now, talking about the impact of HIPAA on banking and Financial Institutions.  I remember as a hospital CIO getting all this stuff from the Medical Banking Project and wondering what it had to do with me - - I used to send it on the revenue cycle people, who in turn, I'm sure, wondered what it had to do with them . . .  That was probably the early 2000’s.  Now we know.

Today’s healthcare providers must continue to diligently require business associate contracts from their financial institution partners when there is access, use or disclosure of personal health information (PHI).  This happens in cash management with lockbox arrangements, with EDI operations and in other areas.  Here’s an example:  when a bank’s lockbox is used to gather, collect and streamline payments and it includes processing the Explanation of Benefits (EOBs), this will result...