Under what conditions are Focus CFO Franchisees authorized to execute a BAA?
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 severely restricted in their ability to execute Business Associate Agreements (BAA). Franchisees are never authorized to execute a BAA as prepared by the client. Focus CFO maintains a standard BAA for use when a client requires one.
Focus CFO franchisees are only authorized to execute a BAA when it is prepared through Focus CFO's centralized preparation process. This means the franchisee must use the standard BAA provided by Focus CFO and cannot alter it or use a client-provided version.
Furthermore, when a BAA is required with a client, Focus CFO also requires franchisees to execute additional documentation. This documentation confirms that the franchisee is aware of the BAA's requirements and will maintain ongoing compliance with Focus CFO's policies and procedures related to clients with a BAA in place. This ensures that franchisees understand their obligations under the BAA and adhere to Focus CFO's standards for handling sensitive client information.