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Does Focus CFO have a standard BAA that can be provided to a client?

Q: Does Focus CFO have a standard BAA that can be provided to a client?

- 3. 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)

Focus_Cfo Franchise · 2025 FDD

Answer from 2025 FDD Document

1. 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, Focus CFO has a standard Business Associate Agreement (BAA) that franchisees can provide to clients when a BAA is required. However, franchisees are not authorized to execute a BAA prepared by the client.

Instead, Focus CFO franchisees are only authorized to execute a BAA that has been prepared through Focus CFO's centralized preparation process. In addition, when a BAA is required with a client, franchisees must execute additional documentation for Focus CFO, acknowledging their awareness 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 requirement ensures that all BAAs used by Focus CFO and its franchisees meet the company's standards and comply with applicable regulations, such as HIPAA. By centralizing the preparation and approval of BAAs, Focus CFO maintains control over these critical legal documents and reduces the risk of non-compliance or inconsistencies that could harm the brand or its clients. This also protects the franchisee by ensuring they are using a legally sound document.

Disclaimer: This information is extracted from the 2025 Franchise Disclosure Document and is provided for research purposes only. It does not constitute legal or financial advice. Consult with a franchise attorney before making any investment decisions.

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