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Business Associate Agreement
Reimbursement Review and Revenue-Cycle Support
1. Purpose
This Business Associate Agreement (“Agreement”) is entered into between the Covered Entity identified above and OriNova Group (“Business Associate”). The Agreement permits OriNova Group to perform reimbursement review, reconciliation, claim analysis, and related reporting services while establishing responsibilities for protected health information (“PHI”).
2. Permitted Uses and Disclosures
OriNova Group may use or disclose PHI only as necessary to perform the services described in the controlling service agreement, as required by law, or as otherwise authorized in writing by the Covered Entity.
Permitted activities may include:
- Reviewing approved EOB, ERA, denial, claim, payment-posting, and reimbursement records.
- Identifying potential underpayments, denials, posting concerns, and reconciliation gaps.
- Preparing analytical reports, discrepancy logs, and recommended follow-up items.
- Supporting the Covered Entity’s reimbursement-review workflow within the agreed project scope.
3. Safeguards
OriNova Group will use reasonable administrative, technical, and physical safeguards appropriate to the agreed workflow. Access to PHI will be limited to authorized persons and to the minimum information reasonably necessary to perform the services.
4. Restrictions
Unless separately authorized in writing, OriNova Group will not use PHI for purposes unrelated to the services, access clinic bank accounts, alter medical billing codes, submit insurance claims, or disclose PHI outside the permitted workflow.
5. Reporting of Incidents
OriNova Group will report to the Covered Entity any known unauthorized use or disclosure of PHI, security incident, or breach involving unsecured PHI without unreasonable delay and will provide available information needed for the Covered Entity’s response.
6. Subcontractors
OriNova Group will require applicable subcontractors that create, receive, maintain, or transmit PHI on its behalf to agree to appropriate restrictions, conditions, and safeguards.
7. Access, Amendment, and Accounting Support
To the extent applicable to records maintained by OriNova Group, OriNova will reasonably support the Covered Entity’s obligations involving access, amendment, and accounting of disclosures.
8. Covered Entity Responsibilities
The Covered Entity will identify the approved project scope, provide only the information needed for the engagement, use the agreed secure transfer method, and notify OriNova Group of relevant privacy restrictions or changes that affect the services.
9. Term and Termination
This Agreement begins on the Effective Date and remains in effect while OriNova Group performs services involving PHI. Either party may terminate the Agreement as permitted by the controlling service agreement or applicable law. Upon termination, OriNova Group will return or securely destroy PHI when feasible, subject to applicable legal, contractual, technical, and retention requirements.
10. General Terms
This Agreement is incorporated into the parties’ controlling service agreement. If a conflict concerns PHI obligations, this Agreement controls for that issue. Amendments must be in writing and accepted by both parties.
11. Signatures
| Covered Entity | OriNova Group |
|---|---|
| Legal Name: ___________________________ Representative: ________________________ Title: _________________________________ Signature: _____________________________ Date: _________________________________ |
Legal Name: OriNova Group Representative: Evelyn T. Douglas Title: Founder / Authorized Representative Signature: _____________________________ Date: _________________________________ |