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
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
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.
Laboratory Accreditation Program
325 Waukegan Road
Northfield, Illinois 60093-2750