What must the Healthsource Chiropractic Business Associate ensure regarding subcontractors who handle PHI?

According to the 2025 Healthsource Chiropractic FDD, if applicable, the Business Associate must ensure that any subcontractors or agents that create, receive, maintain, or transmit Protected Health Information (PHI) or electronic PHI on behalf of the Business Associate agree to the same restrictions, conditions, and requirements that apply to the Business Associate with respect to such information. Additionally, the Business Associate will enter into a business associate agreement that complies with HIPAA requirements with any and all subcontractors to disclose PHI to them.

This requirement ensures that all parties handling PHI, including subcontractors, adhere to the same standards of privacy and security as the Business Associate. This is crucial for maintaining compliance with HIPAA regulations and protecting patient information. The franchisee, as the Covered Entity, needs to be aware that Healthsource Chiropractic, as the Business Associate, is obligated to enforce these standards on its subcontractors.

For a prospective Healthsource Chiropractic franchisee, this means understanding that Healthsource Chiropractic must have agreements in place with its subcontractors to protect patient data. It also implies that the franchisee should verify that Healthsource Chiropractic is fulfilling this obligation to maintain HIPAA compliance. This requirement is not unusual in the franchise industry, particularly in healthcare-related franchises, as maintaining patient privacy and data security is paramount.

It is important to note that HealthCore Technology, LLC and HS Worx are subcontractors of the Covered Entity (the franchisee), not the Business Associate (Healthsource Chiropractic).