I am checking the BAAs for our facility. I don’t see a Gap Analysis attached to their BAAs. The ones that I have to resend for a new one, has to include the Gap Analysis when sent back to us. Is this correct?
October 16, 2017

Yes, technically, they are required to have had one, but you can just ask them to certify that they have had one, and verify that it was recent. Attach the certification form or letter to their BAA.

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