What policies and procedures must Focus CFO Franchisees comply with regarding clients where a BAA is in place?
Focus_Cfo Franchise · 2025 FDDAnswer from 2025 FDD Document
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- Business Associate Agreements (BAA). In accordance with Focus CFO policy, Franchisees are never authorized to execute a BAA as prepared by the client. Focus CFO has a standard BAA that can be provided to a client, in cases when a BAA is required by the client. Franchisees are authorized to execute a BAA only when prepared through Focus CFO's centralized preparation process only. When a BAA is required with a client, Franchisees are also asked to execute additional documentation for Focus CFO indicating the Franchisee is aware of the requirements of the BAA and will be in ongoing compliance with Focus CFO policies and procedures surrounding clients where a BAA in place.
Source: Item 23 — Receipts (FDD pages 37–126)
What This Means (2025 FDD)
According to the 2025 Focus CFO Franchise Disclosure Document, franchisees are required to adhere to specific policies and procedures when dealing with clients that require a Business Associate Agreement (BAA). Franchisees are not authorized to execute a BAA prepared by the client. Instead, Focus CFO provides a standard BAA for use in such cases.
To ensure compliance, Focus CFO requires that all BAAs be prepared through its centralized process. This means the franchisee must use the Focus CFO-approved BAA rather than one provided by the client. Furthermore, franchisees must also sign additional documentation for Focus CFO, acknowledging their understanding of the BAA requirements and their commitment to ongoing compliance with Focus CFO's policies and procedures related to clients with a BAA in place.
This policy is in place to protect sensitive client information and ensure that all franchisees adhere to consistent standards of data privacy and security. By centralizing the BAA preparation process and requiring franchisees to acknowledge their compliance obligations, Focus CFO aims to minimize the risk of data breaches and maintain the integrity of its brand. This also ensures that Focus CFO maintains control over these sensitive agreements and can ensure compliance with all applicable laws and regulations.
For a prospective franchisee, this means they must be diligent in following Focus CFO's established protocols for handling clients who require a BAA. Failure to comply with these policies could result in penalties or other repercussions, as Focus CFO retains the right to modify these provisions with 30 days' notice. Franchisees should familiarize themselves with the Focus CFO Playbook, which contains mandatory specifications, standards, operating procedures and rules that Focus CFO periodically prescribes for franchisees.