HomeMy WebLinkAboutVIII-07 Authorize Signature - Agreement for Professional Services and Business Associate Addendum for Protected Health Information with Emergency Services PerspectivesCity of Hastings 101 Fourth Street East Hastings, MN 55033-1944 Phone: 651-480-2350 www.hastingsmn.gov
City Council Memorandum
To: Mayor Fasbender & City Council Members
From: John Townsend, Fire Chief
Date: August 15, 2023
Item: Approve Agreement for Professional Services and Business Associate Addendum for Protected
Health Information with Emergency Service Perspectives.
Council Action Requested:
Approve Professional Services Agreement and Addendum for Protected Health Information with Emergency
Service Perspectives.
Background Information:
The agreement with Emergency Service Perspectives is part of upgrading the Image Trend records
management system. The addendum is for access to our records management system and protected health
information.
Financial Impact: 2023 budgeted records management upgrade; no impact to budget
Advisory Commission Discussion: N/A
Council Committee Discussion: N/A
Attachments: 1. Professional Services Agreement
2. Business Associate Addendum
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PROFESSIONAL SERVICES AGREEMENT
This PROFESSIONAL SERVICES AGREEMENT (“Agreement”) made this 21st day
of August 2023 (“Effective Date”), by and between the CITY OF HASTINGS, a Minnesota
municipal corporation (“City”) and EMERGENCY SERVICE PERSPECTIVES (ESP), a
Minnesota business (“Consultant”).
IN CONSIDERATION OF THEIR MUTUAL COVENANTS THE PARTIES
AGREE AS FOLLOWS:
1. CONTRACT DOCUMENTS. The Contract consists of the following documents:
A. This Professional Services Agreement;
B. Business Associate Addendum
2. SCOPE OF SERVICES. The City retains Consultant and Consultant agrees to
provide the following services (the “Project”):
A. From the date of this Agreement through one calendar year, Consultant shall:
i. Provide the City with five (5) Arc GIS pre-built Dashboards,
including departmental customizations without additional data fields
(“Dashboard”).
ii. Provide hosting services for the Dashboards.
iii. Present ten (10) monthly RMS/GIS in-person meetings lasting 90 to
150 minutes long (“Trainings”). ESP and the City will work
cooperatively to determine the topics of and schedule the Trainings
to best meet the City’s needs.
3. COMPENSATION.
A. For Project services, the City shall pay Consultant as follows:
i. Training sessions and dashboards are a combination price.
Dashboard hosting comes with the trainings. Package price is $5000
for one calendar year. The dashboards are software as a service. This
is a one-year agreement on hosting this software. Trainings will be
completed monthly for 10 months. If additional training is requested,
a new contract will be offered. The City will pay this amount in one
payment. This amount will be paid in accordance with Paragraph
3.C.
B. Consultant shall be paid at a rate of $150.00 per hour for any work requested
and performed above and beyond the scope of the Project. Such hourly rate
will be effective for the Term of the Agreement. City will receive a formal
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proposal before any billable work is performed above and beyond the scope
of this Agreement.
C. The City will pay Consultant within thirty (30) days upon receipt of a
properly itemized invoice for work completed, unless the City has a good
faith dispute over the amount of the bill, in which case the City must pay
the amount that is not in dispute.
4. TERM. The term of this Agreement shall be effective on the Effective Date of this
Agreement for a Term of one year. This Agreement will not be automatically renewed or extended.
This Agreement may be extended upon mutual written agreement of the parties. Upon the
completion of the term of this Agreement, the City shall be liable to Consultant for services
performed and unpaid under this Agreement.
5. DOCUMENTS. The City shall be the owner of all documents, reports, studies,
analysis and the like prepared by the Consultant in conjunction with this contract. Except as
provided herein, Consultant shall exclusively own all work Consultant provides to the City, including
exclusive rights to dashboard designs and lay-outs. The City agrees not to copy, retain, or share
dashboards owned or developed by Consultant, unless required pursuant to the Minnesota
Government Data Practices Act, Minn. Stat. Ch. 13. The City shall use its best efforts to protect
any data identified as trade secret data as confidential data.
6. COMPLIANCE WITH LAWS AND REGULATIONS. In providing services
hereunder, Consultant shall abide by all statutes, ordinances, rules and regulations pertaining to
the provisions of services to be provided.
7. STANDARD OF CARE. Consultant shall exercise the same degree of care, skill,
and diligence in the performance of the services as is ordinarily possessed and exercised by a
professional consultant under similar circumstances. No other warranty, expressed or implied, is
included in this Agreement. The City shall not be responsible for discovering deficiencies in the
accuracy of Consultant’s services.
8. INSURANCE. Consultant shall secure and maintain a professional liability
insurance policy. Said policy shall insure payment of damages for legal liability arising out of the
performance of professional services for the City, in the insured's capacity as Consultant, if such
legal liability is caused by an intentional or negligent act, error or omission of the insured or any
person or organization for which the insured is legally liable. The policy shall provide minimum
limits of $1,000,000.00 per incident with a deductible maximum of $125,000.00.
Before commencing work, Consultant shall provide the City a certificate of insurance
evidencing the required insurance coverage in a form acceptable to City. The certificate shall
provide that such insurance cannot be cancelled until thirty (30) days after the City has received
written notice of the insurer’s intention to cancel this insurance.
9. INDEPENDENT CONTRACTOR. The City hereby retains Consultant as an
independent contractor upon the terms and conditions set forth in this Agreement. Consultant is not
an employee of the City and is free to contract with other entities as provided herein. Consultant
shall be responsible for selecting the means and methods of performing the work. Consultant shall
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furnish any and all supplies, equipment, and incidentals necessary for Consultant's performance
under this Agreement. The City and Consultant agree that Consultant shall not at any time or in
any manner represent that Consultant or any of Consultant's agents or employees are in any manner
agents or employees of the City. Consultant shall be exclusively responsible under this Agreement
for Consultant's own FICA payments, workers compensation payments, unemployment
compensation payments, withholding amounts, and/or self-employment taxes if any such
payments, amounts, or taxes are required to be paid by law or regulation.
10. ENTIRE AGREEMENT. This Agreement supersedes all oral agreements and
negotiations between the parties relating to the subject matter hereof as well as any previous
agreements presently in effect between the parties relating to the subject matter hereof. Any
alterations, amendments, deletions, or waivers of the provisions of this Agreement shall be valid
only when expressed in writing and duly signed by the parties, unless otherwise provided herein.
11. CONTROLLING LAW. This Agreement shall be governed by and construed in
accordance with the laws of the State of Minnesota. In the event of litigation, the exclusive venue
shall be in the District Court of the State of Minnesota for Dakota County.
12. ASSIGNMENT. Neither party shall assign this Agreement, or any interest arising
herein, without the written consent of the other party.
13. WAIVER. Any waiver by either party of a breach of any provisions of this
Agreement shall not affect, in any respect, the validity of the remainder of this Agreement.
14. MINNESOTA GOVERNMENT DATA PRACTICES ACT. Consultant must
comply with the Minnesota Government Data Practices Act, Minnesota Statutes Chapter 13, as it
applies to (1) all data provided by the City pursuant to this Agreement, and (2) all data, created,
collected, received, stored, used, maintained, or disseminated by the Consultant pursuant to this
Agreement. Consultant is subject to all the provisions of the Minnesota Government Data Practices
Act, including but not limited to the civil remedies of Minnesota Statutes Section 13.08, as if it
were a government entity. In the event Consultant receives a request for data related in any way to
this agreement or the services provided hereunder, Consultant must immediately notify the City.
Consultant shall not release any data without the written consent of the City. Consultant agrees to
defend, indemnify, and hold the City, its officials, officers, agents, employees, and volunteers
harmless from any claims resulting from Consultant’s officers’, agents’, partners’, employees’,
volunteers’, assignees’ or subcontractors’ unlawful disclosure and/or use of protected data. The
terms of this paragraph shall survive the cancellation or termination of this Agreement.
15. TERMINATION OF THE AGREEMENT. Either City or Consultant may
terminate this Agreement upon thirty (30) days’ written notice (including delivery by facsimile or
electronic mail) to the other party or as provided in Article 4 of the Business Associate Addendum.
IN WITNESS WHEREOF, the parties have entered into this Agreement on the dates shown
below. By signing below each party specifically acknowledges that it has read this Agreement, that
it has been advised to review the terms of this Agreement with legal counsel, that it has received all
necessary approvals from governing bodies to enter into such Agreement, and that it agrees to be
legally bound by all terms of the Agreement.
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EMERGENCY SERVICE PERSPECTIVES
Dated: , 2023
Brian DesLauriers, Owner ESP
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CITY OF HASTINGS
Mary Fasbender, Mayor
Kelly Murtaugh, City Clerk
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BUSINESS ASSOCIATE ADDENDUM
THIS BUSINESS ASSOCIATE ADDENDUM (“Addendum”), is made and
entered into by and between The City of Hastings, Minnesota (“Covered Entity”) and
Emergency Service Perspectives. (“Business Associate”). This Addendum shall form a
part of all agreements and other engagements as are currently in effect between the parties
under which Protected Health Information (“PHI”) (as defined in Article 1 of this
Addendum) is provided, created or received by Business Associate from or on behalf of
Covered Entity, and shall supersede and replace any business associate agreement or
amendment previously entered into between Covered Entity and Business Associate in
accordance with the requirements of HIPAA (as defined below) and/or the HITECH Act
(as defined below). This Addendum is effective as of the effective date of the Professional
Services Agreement (the “Effective Date”).
RECITALS
WHEREAS, in connection with the performance of their respective obligations
under the terms of the Professional Services Agreement, Covered Entity may disclose
certain information to Business Associate, and Business Associate may use and/or disclose
certain information, some of which may constitute PHI; and
WHEREAS, Covered Entity and Business Associate intend to protect the privacy
and provide for the security of PHI disclosed to, or created, utilized or disclosed by,
Business Associate pursuant to the Professional Services Agreement in compliance with
the Health Insurance Portability and Accountability Act of 1996, and its implementing
regulations and guidance issued by the Secretary of the U.S. Department of Health and
Human Services (the “Secretary”), all as amended from time to time (“HIPAA”), as well
as the requirements of the Health Information Technology for Economic and Clinical
Health Act, as incorporated in the American Recovery and Reinvestment Act of 2009, and
its implementing regulations and guidance issued by the Secretary, all as amended from
time to time (the “HITECH Act”), and other applicable laws;
The parties do hereby agree as follows:
Article 1: Definitions
1.1 Definitions. For the purposes of this Addendum, the following defined terms shall
have the following definitions. All capitalized terms used in this Addendum but
not otherwise defined herein shall have the meaning given in HIPAA or the
HITECH Act, as applicable.
(a) “Breach” has the meaning given to such term under HIPAA and the
HITECH Act, including, but not limited to, at § 13400(1) of the HITECH
Act and 45 CFR § 164.402.
(b) “Data Aggregation” has the meaning given to such term under the Privacy
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Standards (as defined below), including, but not limited to, at 45 CFR §
164.50l.
(c) “Designated Record Set” has the meaning given to such term under the
Privacy Standards, including, but not limited to, at 45 CFR § 164.501.
(d) “Health Care Operations” has the meaning given to such term under the
Privacy Standards, including, but not limited to, at 45 CFR § 164.501.
(e) “Limited Data Set” has the meaning given to such term under the Privacy
Standards, including, but not limited to, at 45 CFR § 164.514.
(f) “Privacy Standards” means the HIPAA Privacy Rule and HIPAA Security
Rule codified at 45 CFR Parts 160, 162 and 164.
(g) “Protected Health Information” or “PHI” has the meaning given to such
term under HIPAA, the HITECH Act, and the Privacy Standards, including,
but not limited to, at 45 CFR § 160.103.
(h) “Unsecured Protected Health Information” has the meaning given to
such term under HIPAA and the HITECH Act, including, but not limited
to, at § 13402(h) of the HITECH Act and 45 CFR §164.402.
Article 2: Duties of Business Associate
2.1 Compliance with Privacy Provisions. Business Associate shall only use and
disclose PHI in performance of its obligations under the Professional Services
Agreement and as permitted or required by law. Business Associate agrees to be
in compliance with each applicable requirement of 45 CFR § 164.504(e) and all
requirements of the HITECH Act applicable to Business Associate.
2.2 Compliance with Security Provisions. Business Associate shall: (a) implement
and maintain administrative safeguards as required by 45 CFR § 164.308, physical
safeguards as required by 45 CFR § 164.310 and technical safeguards as required
by 45 CFR § 164.312; (b) implement and document reasonable and appropriate
policies and procedures as required by 45 CFR § 164.316; (c) use its best efforts
to implement and maintain technologies and methodologies that render PHI
unusable, unreadable or indecipherable to unauthorized individuals as specified in
the HITECH Act; and (d) be in compliance with all requirements of the HITECH
Act related to security and applicable to Business Associate.
2.3 Breach of Unsecured PHI.
(a) With respect to any suspected or actual unauthorized acquisition, access,
use or disclosure (“Acquisition”) of Covered Entity’s PHI by Business
Associate, its agents or subcontractors, and/or any Acquisition of data in
violation of any applicable federal or state law, Business Associate shall (i)
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investigate such Acquisition; (ii) determine whether such Acquisition
constitutes a reportable Breach under HIPAA, the HITECH Act, and/or
applicable federal or state law ; (iii) document and retain its findings under
clauses (i) and (ii); and (iv) take any action pertaining to such Acquisition
required by applicable federal or state law.
(b) If Business Associate discovers that a Breach has occurred, Business
Associate shall notify Covered Entity in writing without unreasonable delay
and in no case later than five (5) days after discovery of the Breach.
Business Associate’s written notice shall include all available information
required by 45 CFR § 164.410 and other applicable law. Business
Associate’s written report shall be promptly supplemented with any new or
additional information. Business Associate agrees to cooperate with
Covered Entity in meeting Covered Entity’s obligations under the HITECH
Act and other applicable law with respect to such Breach. Covered Entity
shall have sole control over the timing and method of providing notification
of such Breach to the affected individual(s) or others as required by the
HITECH Act and other applicable law.
2.4 Permitted Uses of PHI. Satisfactory performance of its obligations under the
Professional Services Agreement by Business Associate may require Business
Associate to receive or use PHI obtained from Covered Entity, or created or
received by Business Associate on behalf of Covered Entity; provided, however,
that Business Associate shall not use PHI other than for the purpose of performing
Business Associate’s obligations under the Professional Services Agreement
(including this Addendum), as permitted or required under the Professional
Services Agreement (including this Addendum), or as required by law. Business
Associate shall not use PHI in any manner that would constitute a violation of
HIPAA if so used by Covered Entity.
2.5 Permitted Disclosures of PHI. Business Associate shall not disclose PHI other
than for the purpose of performing Business Associate’s obligations under the
Professional Services Agreement (including this Addendum), as permitted or
required under the Professional Services Agreement (including this Addendum), or
as required by law. Business Associate shall not disclose PHI in any manner that
would constitute a violation of HIPAA if so disclosed by Covered Entity. To the
extent that Business Associate discloses PHI to a third party in carrying out its
obligations under the Professional Services Agreement, Business Associate must
obtain, prior to making any such disclosure, (i) reasonable assurances from such
third party that such PHI will be held confidential as provided pursuant to this
Addendum and only disclosed as required by law or for the purposes for which it
was disclosed to such third party, and (ii) an agreement from such third party to
immediately notify Business Associate of any breaches of confidentiality of the
PHI, to the extent the third party has obtained knowledge of such breach.
2.6 Minimum Necessary. Business Associate shall limit its use, disclosure or request
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of PHI to only the minimum necessary as required by law.
2.7 Retention of PHI. Unless otherwise specified in the Professional Services
Agreement, Business Associate shall maintain and retain PHI for the term of the
Professional Services Agreement, and make such PHI available to Covered Entity
as set forth in this Addendum.
2.8 Safeguarding PHI. Business Associate shall use appropriate safeguards to prevent
the use or disclosure of PHI other than as permitted by the Professional Services
Agreement and this Addendum. Business Associate will appropriately safeguard
electronic PHI in accordance with the standards specified at 45 CFR § 164.314(a).
In particular, Business Associate will implement administrative, physical and
technical safeguards that reasonably and appropriately protect the confidentiality,
integrity and availability of electronic PHI that it creates, receives, maintains or
transmits on behalf of Covered Entity.
2.9 Agents and Subcontractors. Business Associate shall ensure that any agents
(including subcontractors) of Business Associate to whom Business Associate
provides PHI received from Covered Entity, or PHI created or received by Business
Associate on behalf of Covered Entity, agree in writing to the same restrictions and
conditions that apply to Business Associate with respect to such PHI, including the
requirement to implement administrative, physical and technical safeguards that
reasonably and appropriately protect the confidentiality, integrity and availability
of PHI. Business Associate shall implement appropriate sanctions against agents
and subcontractors that violate such restrictions and conditions, including
termination of the agency or subcontractor relationship, if feasible, and shall
mitigate the effects of any such violations.
2.10 Reporting Unauthorized Use or Disclosure. Business Associate shall report in
writing to Covered Entity any use or disclosure of PHI not provided for under the
Professional Services Agreement or this Addendum as soon as possible after
Business Associate becomes aware of such an incident but in no case later than five
(5) days after the date on which Business Associate becomes aware of any such
incident; provided, however, that the Parties acknowledge and agree that this
Section constitutes notice by Business Associate to Covered Entity of the ongoing
existence and occurrence of attempted but Unsuccessful Security Incidents (as
defined below). “Unsuccessful Security Incidents” will include, but not be limited
to, pings and other broadcast attacks on Business Associate’s firewall, port scans,
unsuccessful log-on attempts, denials of service and any combination of the above,
so long as no such incident results in unauthorized access, use or disclosure of PHI.
Business Associate shall take (i) prompt corrective action to cure any deficiencies
that caused the unauthorized use or disclosure, and (ii) any corrective action
required by applicable federal and state law.
2.11 Access to Information. Within five (5) days of Covered Entity’s request, Business
Associate shall provide Covered Entity with access to Covered Entity’s PHI
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maintained by Business Associate or its agents or subcontractors to enable Covered
Entity to fulfill its obligations under the Privacy Standards, including, but not
limited to, 45 CFR § 164.524.
2.12 Availability of PHI for Amendment. The parties acknowledge that the Privacy
Standards permit an individual who is the subject of PHI to request certain
amendments of their records. Upon Covered Entity’s request for an amendment of
PHI or a record about an individual contained in a Designated Record Set, but not
later than five (5) days after receipt of such request, Business Associate and its
agents or subcontractors shall make such PHI available to Covered Entity for
amendment and incorporate any such amendment to enable Covered Entity to fulfill
its obligations under the Privacy Standards, including, but not limited to, 45 CFR §
164.526. If any individual requests an amendment of PHI directly from Business
Associate or its agents or subcontractors, Business Associate must notify Covered
Entity in writing within five (5) days of the request. Covered Entity has the sole
authority to deny a request for amendment of PHI received or created under the
terms of the Professional Services Agreement and maintained by Business
Associate or its agents or subcontractors.
2.13 Accounting of Disclosures. Upon Covered Entity’s request, Business Associate,
its agents and subcontractors shall make available the information required to
provide an accounting of disclosures to enable Covered Entity to fulfill its
obligations under the Privacy Standards, including, but not limited to, 45 CFR §
164.528. For this purpose, Business Associate shall retain a record of disclosure of
PHI for at least six (6) years from the date of disclosure. Business Associate agrees
to implement a process that allows for an accounting to be collected and maintained
by Business Associate and its agents or subcontractors for at least six (6) years prior
to the request, but not before the effective date of the Professional Services
Agreement. At a minimum, such information shall include: (i) the date of
disclosure; (ii) the name of the entity or person who received PHI and, if known,
the address of the entity or person; (iii) a brief description of PHI disclosed; and
(iv) a brief statement of the purpose of the disclosure that reasonably informs the
individual of the basis for the disclosure, or a copy of the individual’s authorization,
or a copy of the written request for disclosure. Where a request for an accounting
is delivered directly to Business Associate or its agents or subcontractors, Business
Associate shall within five (5) days of a request forward it to Covered Entity in
writing. It shall be Covered Entity’s responsibility to prepare and deliver any such
reply to the requested accounting.
2.14 Agreement to Restriction on Disclosure. If Covered Entity is required to comply
with a restriction on the disclosure of PHI pursuant to § 13405 of the HITECH Act,
then Covered Entity shall provide written notice to Business Associate of the name
of the individual requesting the restriction and the PHI affected thereby. Business
Associate shall, upon receipt of such notification, not disclose the identified PHI to
any health plan for the purposes of carrying out Payment or Health Care Operations,
except as otherwise required by law.
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2.15 Accounting of Disclosures of Electronic Health Records (“EHR”). If Business
Associate is deemed to use or maintain an EHR on behalf of Covered Entity, then
Business Associate shall maintain an accounting of any disclosures made through
an EHR for Treatment, Payment and Health Care Operations, as required by law.
Upon request by Covered Entity, Business Associate shall provide such accounting
to Covered Entity in the time and manner specified by law. Alternatively, if
Covered Entity responds to an individual’s request for an accounting of disclosures
made through an EHR by providing the requesting individual with a list of all
business associates acting on behalf of Covered Entity, then Business Associate
shall provide such accounting directly to the requesting individual in the time and
manner specified by the HITECH Act.
2.16 Access to Electronic Health Records. If Business Associate is deemed to use or
maintain an EHR on behalf of Covered Entity with respect to PHI, then, to the
extent an individual has the right to request a copy of the PHI maintained in such
EHR pursuant to 45 CFR § 164.524 and makes such a request to Business
Associate, Business Associate shall provide such individual with a copy of the PHI
in the EHR in an electronic format and, if the individual so chooses, transmit such
copy directly to an entity or person designated by the individual. Business
Associate may charge a fee, not to exceed Contractor’s labor costs to respond, to
the individual for providing the copy of the PHI. The provisions of 45 CFR
§ 164.524, including the exceptions to the requirement to provide a copy of PHI,
shall otherwise apply and Business Associate shall comply therewith as if Business
Associate were Covered Entity. At Covered Entity’s request, Business Associate
shall provide Covered Entity with a copy of an individual’s PHI maintained in an
EHR in an electronic format and in a time and manner designated by Covered Entity
in order for Covered Entity to comply with 45 CFR § 164.524, as amended by the
HITECH Act.
2.17 Remuneration for PHI. Business Associate agrees that it shall not, directly or
indirectly, receive remuneration in exchange for any PHI of Covered Entity except
as otherwise permitted by law.
2.18 Limitations on Use of PHI for Marketing Purposes. Business Associate shall
not use or disclose PHI for the purpose of making a communication about a product
or service that encourages recipients of the communication to purchase or use the
product or service, unless such communication: (a) complies with the requirements
of subparagraph (i), (ii) or (iii) of paragraph (1) of the definition of marketing
contained in 45 CFR § 164.501, and (b) complies with the requirements of
subparagraphs (A), (B) or (C) of § 13406(a)(2) of the HITECH Act. Covered Entity
shall cooperate with Business Associate to determine if the foregoing requirements
are met with respect to any such marketing communication.
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2.19 Governmental Access to Books and Records. For purposes of determining
Covered Entity’s compliance with the HIPAA, Business Associate agrees to make
available to the Secretary its internal practices, books, and records relating to the
use and disclosure of PHI received from Covered Entity, or created or received by
Business Associate on behalf of Covered Entity.
2.20 Data Ownership. Business Associate acknowledges that Business Associate has
no ownership rights with respect to the PHI.
2.21 Insurance. Business Associate shall maintain commercial general liability
insurance, with commercially reasonable liability limits, that includes coverage for
damage to persons or property arising from any breach of the terms of this
Addendum.
2.22 Audits, Inspection and Enforcement. Within ten (10) days of a written request
by Covered Entity, Business Associate and its agents or subcontractors shall allow
Covered Entity to conduct a reasonable inspection of the facilities, systems, books,
records, agreements, policies and procedures relating to the use or disclosure of PHI
pursuant to this Addendum for the purpose of determining whether Business
Associate has complied with this Addendum; provided, however, that (i) Business
Associate and Covered Entity shall mutually agree in advance upon the scope,
timing and location of such an inspection; (ii) Covered Entity shall protect the
confidentiality of all confidential and proprietary information of Business
Associate to which Covered Entity has access during the course of such inspection;
and (iii) Covered Entity shall execute a nondisclosure agreement, upon terms
mutually agreed upon by the parties, if requested by Business Associate. Covered
Entity and its authorized agents or contractors, may, at Covered Entity’s expense,
examine Business Associate’s facilities, systems, procedures and records as may
be necessary for such agents or contractors to certify to Covered Entity the extent
to which Business Associate’s security safeguards comply with HIPAA, the
HITECH Act or this Addendum, to the extent that Covered Entity determines that
such examination is necessary to comply with Covered Entity’s legal obligations
pursuant to HIPAA or the HITECH Act relating to certification of its security
practices. The fact that Covered Entity inspects, or fails to inspect, or has the right
to inspect, Business Associate’s facilities, systems, books, records, agreements,
policies and procedures does not relieve Business Associate of its responsibility to
comply with this Addendum, nor does Covered Entity’s (i) failure to detect or (ii)
detection, but failure to notify Business Associate or require Business Associate’s
remediation of any unsatisfactory practices, constitute acceptance of such practices
or a waiver of Covered Entity’s enforcement rights under the Professional Services
Agreement or this Addendum.
2.23 Return of PHI at Termination. Upon termination of the Professional Services
Agreement, Business Associate shall, where feasible, destroy or return to Covered
Entity all PHI received from Covered Entity, or created or received by Business
Associate or its agents or subcontractors on behalf of Covered Entity. Where return
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or destruction is not feasible, the duties of Business Associate under this Addendum
shall be extended to protect the PHI retained by Business Associate. Business
Associate agrees not to further use or disclose information for which the return or
destruction is infeasible. Business Associate shall certify in writing the destruction
of the PHI and to the continued protection of PHI that is not feasible to destroy.
2.24 Retention of PHI. Business Associate and its contractors or agents shall retain
communications and documents required to be maintained by HIPAA for six (6)
years after termination of the Professional Services Agreement.
2.25 Business Associate’s Performance of Obligations of Covered Entity. To the
extent the Business Associate is to carry out one or more of Covered Entity’s
obligation(s) under the HIPAA Privacy Rule, Business Associate shall comply with
the requirements of the Privacy Rule that apply to Covered Entity when it carries
out such obligation(s).
Article 3: Duties of Covered Entity
3.1 Using Appropriate Safeguards. Covered Entity shall be responsible for using
appropriate safeguards to maintain and ensure the confidentiality, privacy and
security of PHI transmitted to Business Associate pursuant to the Professional
Services Agreement, in accordance with the standards and requirements of HIPAA.
Article 4: Term and Termination
4.1 Term. The provisions of this Addendum shall become effective on the Effective
Date and shall continue in effect until all of the PHI provided by Covered Entity to
Business Associate, or created or received by Business Associate on behalf of
Covered Entity is destroyed or returned to Covered Entity, or, if it is infeasible to
return or destroy the PHI, protections are extended to such information in
accordance with the termination provisions in Section 4.2 of this Addendum.
4.2 Termination by Covered Entity.
(a) A breach by Business Associate of any material provision of this
Addendum, as determined by Covered Entity, shall constitute a material
breach of the Professional Services Agreement and shall provide grounds
for immediate termination of the Professional Services Agreement by
Covered Entity.
(b) If Covered Entity knows of a pattern of activity or practice of Business
Associate that constitutes a material breach or violation of Business
Associate’s obligations under the provisions of this Addendum or another
arrangement and does not terminate the Professional Services Agreement
pursuant to Section 4.2(a) of this Addendum, then Business Associate shall
take reasonable steps to cure such breach or end such violation, as
applicable. If Business Associate’s efforts to cure such breach or end such
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violation are unsuccessful, Covered Entity shall either (i) terminate the
Professional Services Agreement, if feasible or (ii) if termination of the
Professional Services Agreement is not feasible, Covered Entity shall report
Business Associate’s breach or violation to the Secretary.
4.3 Termination by Business Associate. If Business Associate knows of a pattern of
activity or practice of Covered Entity that constitutes a material breach or violation
of Covered Entity’s obligations under the Professional Services Agreement or this
Addendum, then Business Associate shall immediately notify Covered Entity.
With respect to such breach or violation, Business Associate shall (i) take
reasonable steps to cure such breach or end such violation, if possible; or (ii) if such
steps are either not possible or are unsuccessful, upon written notice to Covered
Entity, terminate the Professional Services Agreement; or (iii) if such termination
is not feasible, report Covered Entity’s breach or violation to the Secretary.
4.4 Termination by Either Party. Either party may terminate the Professional
Services Agreement, effective immediately, if (i) the other party is named as a
defendant in a criminal proceeding for a violation of HIPAA, the HITECH Act or
other security or privacy laws, or (ii) a finding or stipulation that the other party has
violated any standard or requirement of HIPAA, the HITECH Act or other security
or privacy laws is made in any administrative or civil proceeding in which the party
has been joined.
Article 5: Miscellaneous
5.1 Acknowledgment. Business Associate recognizes and agrees that it is obligated
by law to comply with the applicable provisions of the HITECH Act.
5.2 Change in Law. The parties agree to promptly enter into negotiations concerning
the terms of the Professional Services Agreement (including this Addendum), and
to negotiate in good faith, if, in either party’s business judgment, modification of
the Professional Services Agreement (including this Addendum) becomes
necessary due to legislative, regulatory, or judicial developments regarding HIPAA
or the HITECH Act. Covered Entity may terminate the Professional Services
Agreement upon thirty (30) days written notice in the event (i) Business Associate
does not promptly enter into negotiations to amend the Professional Services
Agreement when requested by Covered Entity pursuant to this § 5.2, or (ii) Business
Associate does not enter into an amendment to the Professional Services Agreement
providing assurances regarding the safeguarding of PHI that Covered Entity, in its
sole discretion, deems sufficient to satisfy the standards and requirements of
HIPAA and the HITECH Act.
5.3 Disclaimer. Covered Entity makes no warranty or representation that compliance
by Business Associate with HIPAA, the HITECH Act or this Addendum will be
adequate or satisfactory for Business Associate’s own purposes. Business
Associate is solely responsible for all decisions made by Business Associate
regarding the safeguarding of PHI.
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5.4 Assistance in Litigation or Administrative Proceedings. Business Associate
shall make itself, and any subcontractors, employees or agents assisting Business
Associate in the performance of its obligations under the Professional Services
Agreement or this Addendum, available to Covered Entity, at no cost to Covered
Entity, to testify as witness, or otherwise, in the event of litigation or administrative
proceedings being commenced against Covered Entity, its members/shareholders,
managers/directors, officers or employees based upon a claimed violation of
HIPAA or the HITECH Act or other laws relating to security and privacy, except
where Business Associate, or its subcontractor, employee or agent is a named
adverse party.
5.5 No Third-Party Beneficiaries. Nothing express or implied in this Addendum is
intended to confer, nor shall anything herein confer, upon any person other than
Covered Entity, Business Associate and their respective successors or assigns, any
rights, remedies, obligations or liabilities whatsoever.
5.6 Interpretation. Section titles in this Addendum are for convenience only, and shall
not be used in interpreting this Addendum. Any ambiguity in this Addendum shall
be resolved to permit the parties to comply with the requirements of HIPAA and
the HITECH Act. In the event of conflict between the Professional Services
Agreement and this Addendum, the provisions of this Addendum shall prevail.
Any reference in this Addendum to a section in the Standards for Privacy of
Individually Identifiable Health Information at 45 CFR part 160 and part 164,
subparts A and E, the Security Standards for the Protection of Electronic Protected
Health Information at 45 CFR part 164, subpart C, or the HITECH Act means the
section as in effect or as amended.
The parties hereto have executed this Rider on the day and year first above written on the
Professional Services Agreement.
THE CITY OF HASTINGS MN EMERGENCY SERVICE PERSPECTIVES
(Covered Entity) (Business Associate)
By: ____________________________ By: ____________________________
Name: __________________________ Name: BRIAN DESLAURIERS
Title: ___________________________ Title: SOLE PROPRIETOR
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Date: ________________________ Date: 03/19/2023
VIII-07