College of American Pathologists

HIPAA and the CAP Laboratory Accreditation Program

Updated November 3, 2003


HIPAA and the CAP Laboratory Accreditation Program

Some of the HIPAA regulations impact the relationship of entities with the College of American Pathologists as it relates to the CAP Laboratory Accreditation Program. Specifically, the HIPAA privacy rules call for covered entities to enter into written agreements with their business associates, defined as any individuals or organizations that have access to PHI as a result of providing services to that covered entity. Since the CAP may have access to PHI during the inspection and accreditation of an entity, it is considered a business associate of that entity. Thus, in order to comply with HIPAA regulations, the entity will need to enter into a business associate agreement with the CAP.

For your convenience, the CAP has drafted a model agreement that can be used for this purpose. It is written in a simple and concise manner and can be applied to any business associate situation.

If you are accredited by the CAP, we strongly encourage you to use the model agreement to help you comply with the HIPAA business associate requirements.

To enter into a business associate agreement with the CAP, simply complete and sign two copies, and forward them to the address below. A representative of the CAP will sign both copies and return one to your attention for your records within 10 working days.

College of American Pathologists
Laboratory Accreditation Program
325 Waukegan Road
Northfield, Illinois 60093-2750
The CAP will further protect the CAP-accredited entity by informing inspectors and any other personnel who may have access to PHI of their obligation to keep this information confidential and to use such information only within the context of the inspection itself.

Related Links