Memorandum To: All Part D Plans Subject: Final Standard Business Associate Agreement with the TrOOP Facilitator From: Cynthia Tudor, Ph.D., Director, Medicare Drug Benefit GroupBusiness Associate Agreement • January 18th, 2007
Contract Type FiledJanuary 18th, 2007Attached please find a standard language business associates agreement to be executed with the TrOOP Facilitation Contractor. Consistent with our final COB guidelines and with the HIPAA Privacy Rule (45 CFR Parts 160 and 164), the TrOOP Facilitation Contractor will be a business associate of Part D plans for the purpose of performing TrOOP and COB functions when it receives data directly from the Part D plan. Currently, this may happen if a plan reverses an N transaction. Accordingly, each Part D plan is required to execute a business associate agreement with the TrOOP Facilitation Contractor covering TrOOP and COB functions.