What does Focus Cfo require franchisees to acknowledge regarding BAA requirements?
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 never authorized to execute a Business Associate Agreement (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, Focus CFO also requires franchisees to execute additional documentation indicating that the franchisee is aware of the requirements of the BAA. This documentation confirms the franchisee will remain in ongoing compliance with Focus CFO policies and procedures surrounding clients where a BAA is in place.
This requirement ensures that all BAAs are standardized and compliant with Focus CFO's policies, reducing the risk of non-compliance and protecting client confidentiality. It also places the responsibility on the franchisee to understand and adhere to these policies, highlighting the importance of ongoing compliance.