GE HEALTHCARE BAA (GE EXECUTED).PDF
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MARICOPA COUNTY By and Through its Department of Public Health (MCDPH) BUSINESS ASSOCIATE AGREEMENT This Business Associate Agreement (“Agreement”) effective on the last signature date below, is entered into by and between GE Healthcare through its affiliates including but not limited to GE Precision Healthcare LLC, GE Medical Systems, Ultrasound & Primary Care Diagnostics, LLC, GE Medical Systems Information Technologies, Inc., Datex- Ohmeda, Inc., OEC Medical Systems, Inc., GE Healthcare IITS USA Corp., GE Healthcare Inc., Medi-Physics Inc. and GE Healthcare Bio-Sciences Corp., (“Business Associate” or “Associate”) as a business associate of the MARICOPA COUNTY, a covered entity, with an address at 4041 N. Central Avenue, Suite 1400, Phoenix, AZ 85012, on behalf of itself and its subsidiaries listed on Schedule A attached hereto (“Covered Entity”) under the Health Insurance Portability and Accountability Act of 1996, Pub. Law 104-191 (Aug. 21, 1996), its implementing regulations (“HIPAA”), the Health Information Technology for Economic and Clinical Health its implementing regulations (“HITECH”) Act, and pursuant to the Contract or Engagement Letter (as defined below) between Associate and MARICOPA COUNTY. Associate and MARICOPA COUNTY are referred to individually as “Party” and collectively as “Parties”. The Parties have entered into, and may in the future enter into, one or more agreements (”Contract” or “Engagement Letter”), under which MARICOPA COUNTY may make available and/or transfer to Associate Protected Health Information (“PHI”) of Individuals in conjunction with Services, which Associate will Use or Disclose only in accordance with this Agreement. Associate and MARICOPA COUNTY agree to the terms and conditions of this Agreement in order to comply with the Use, Disclosure and handling of PHI under the HIPAA Standards for Privacy of Individually Identifiable Health Information, 45 C.F.R. Part 160 and Part 164, Subpart E (“Privacy Standards”) HIPAA Security Standards, 45 C.F.R. Part 160 and Part 164, Subpart C (“Security Standards”), both as amended from time to time and HITECH. This Agreement shall supplement and/or amend each of the Contract or Engagement Letter(s) only with respect to Associate’s receipt, Use, Disclosure, and creation of PHI under the Contract or Engagement Letter(s) to allow both Parties to comply with HIPAA and HITECH. Unless otherwise provided, all capitalized terms in this Agreement will have the same meaning as provided under the Privacy Standards and Security Standards, in effect or as amended. Associate and MARICOPA COUNTY will comply with the terms of this Agreement for the duration of the last Contract or Engagement Letter or till the termination of this Agreement. Upon the compliance date of any final regulation or amendment to final regulation promulgated by the Secretary of Health and Human Services that affects Associate’s Use or Disclosure of PHI, the Parties mutually agree to enter into good faith negotiations and to take such reasonable action as is necessary to amend this Agreement in order for MARICOPA COUNTY to comply with such final regulation or amendment to final regulation. Definitions for terms in this Agreement: 1. Business Associate or Associate means an entity that has been defined in 45 C.F.R. § 160.103. 2. Contractors of Business Associate means a person or an entity to whom an Associate delegates a function, activity, or service that the Associate has agreed to perform for a Covered Entity. A contractor of an Associate which creates, receives, maintains, or transmits personal health information on behalf of the business associate is itself a Business Associate and therefore will comply with the terms of this Agreement. For purposes of this Agreement the term “Contractor” includes the Contractor, its subcontractors and its agents. Maricopa County Business Associate Agreement 1 4/3/2015 3. Protected Health Information (“PHI”) shall have the same meaning as the Protected Health Information as defined in 45 C.F.R. § 160.103, limited to the information created or received by Associate from or on behalf of Covered Entity, including, but not limited to EPHI. 4. Individual shall have the meaning set forth in 45 CFR §160.103, including a person who is the subject of the Protected Health Information, and shall include an Individual or entity who qualifies as a personal, legal representative of the person, as the context requires. 5. Privacy Rule shall mean the Standards for Privacy of Individually Identifiable Health Information at 45 CFR Parts 160 and 164, Subparts A and E, as may be amended, modified or superseded, from time to time. 6. Security Rule shall mean the Standards for Security of Individually Identifiable Electronic Health Information at 45 CFR Parts 160 and 164, Subparts A, C and E, as may be amended, modified or superseded, from time to time. 7. Breach shall mean the acquisition, Access, Use or Disclosure of Protected Health Information in a manner not permitted by the HIPAA Privacy Rule, that compromises the security or privacy of the Protected Health Information as defined, and subject to the exception given to such term in 45 C.F.R. § 164.402. 8. Breach Notification Rule shall mean the interim final rule related to breach notification for unsecured Protected Health Information at 45 C.F.R. Parts 160 and 164. 9. Covered Entity shall have the meaning given to such term in 45 C.F.R. § 160.103. 10. Designated Record Set shall have the meaning given to such term under the Privacy Rule at 45 C.F.R. § 164.501. 11. Security Incident shall have the meaning given to such phrase under the Security Rule at 45 C.F.R. § 164.304. 12. Unsecured PHI shall have the meaning given to such phrase under the Breach Notification Rule at 45 C.F.R. § 164.402. 13. Electronic Protected Health Information or ePHI means PHI transmitted by or maintained in Electronic Media and shall have the same meaning given to such term under the Security Rule, including, but not limited to, 45 C.F.R. § 160.103. 14. Electronic Media shall have the same meaning given to such term in 45 C.F.R. § 160.103. 15. Health Information Technology for Economic and Clinical Health (HITECH) Act, as codified at 42 U.S.C. §§ 17921-17954. 16. Secretary shall mean the Secretary of the Department of Health and Human Services or his or her designee. In the event of a conflict between the definitions provided herein and those in HIPAA or HITECH, the definition in HIPAA or HITECH shall prevail. It is agreed by and between the Parties that: 1. Uses and Disclosures of Protected Health Information. Associate will Use and Disclose PHI only for those purposes necessary to perform its duties, obligations and functions under the Contract or Engagement Letter, or as otherwise expressly permitted in this Agreement, Contract or Engagement Letter or as Required by Law. a. Associate will not Use or further Disclose any PHI in violation of this Agreement or in violations of the requirements of Subpart E of 45 C.F.R. Part 164, if done by Covered Entity. Maricopa County Business Associate Agreement 2 4/3/2015 b. Associate may Use PHI to perform data aggregation services relating to the health care operations of Covered Entity as permitted by 45 C.F. R. § 164.504(e) (2) (i) (B). 2. Associate Use or Disclosure of Protected Health Information for its Own Purposes. Associate may Use or Disclose PHI received from MARICOPA COUNTY for Associate’s management and administration, or to carry out Associate’s legal responsibilities. Associate may Disclose PHI received from MARICOPA COUNTY to a third party for such purposes only if: a. The Disclosure is Required By Law; or b. Associate secures reasonable assurance from the receiving party that the receiving party will: (i) hold the PHI confidentially; (ii) Use or Disclose the PHI only as Required by Law or for the purposes for which it was disclosed to the recipient; and (iii) notify the Associate of any breaches in the confidentiality of the PHI. c. Associate may Use and Disclose de-identified health information, if (i) that the de-identification is in compliance with 45 C.F.R. § 164.502(d), and (ii) the de-identified health information meets the standard and implementation specifications for de-identification under 45 C.F.R. § 164.514(a) and (b). d. Associate shall Use and Disclose PHI only to the extent reasonably necessary to accomplish the intended purpose of such PHI. 3. Safeguards. Associate will implement and maintain reasonable and appropriate safeguards and comply, where applicable, with Subpart C of 45 C.F.R. Part 164 with respect to ePHI to prevent any Use or Disclosure of PHI not otherwise permitted in this Agreement. a. Associate also will implement reasonable and appropriate administrative, physical and technical safeguards to protect the Confidentiality, Integrity, and Availability of any electronic protected health information (“ePHI”), if any, that Associate creates, receives, maintains, and transmits on behalf of MARICOPA COUNTY. 4. Reports of Improper Use or Disclosure of Secure or Unsecure Protected Health Information and of Security Incidents and Breaches. Associate will report to MARICOPA COUNTY of any Use or Disclosure of PHI, including any Breach of Unsecured PHI, not permitted by this Agreement between Associate and MARICOPA COUNTY within fifteen (15) business days of Associate’s learning of such Use, Disclosure or Breach. 5. Mitigation of potential harmful effects. Associate shall, to the extent practicable, mitigate all potential harmful effects of a Use, loss or Disclosure of Protected Health Information by Business Associate in violation of the requirements of this Agreement. With the exception of law enforcement delays that satisfy the requirements under 45 C.F.R. § 164.412 or as otherwise required by applicable State law, following the determination of a Breach of Unsecured PHI, notify MARICOPA COUNTY of such Breach in accordance with 45 C.F.R. § 164.410, and exercise commercially reasonable efforts to provide such notice to Covered Entity without unreasonable delay and in no case later than fifteen (15) business days after discovery of the Breach. Promptly following the Associate’s discovery of a Breach, Associate shall provide MARICOPA COUNTY with sufficient information to permit MARICOPA COUNTY to comply with the Breach notification requirements set forth at 45 C.F.R. §164.400 et seq. a. If the following information is known to the Associate, Associate will provide to MARICOPA COUNTY all available information that MARICOPA COUNTY is required to include in its notification to the Individual pursuant to the Breach Notification Rule, including but not limited to: Maricopa County Business Associate Agreement 3 4/3/2015 i. contact information for Individuals who were or who may have been impacted by the Breach (e.g., first and last name, mailing address, street address, phone number, email address); ii. a brief description of the circumstances of the Breach, including the date of the Breach, the date of discovery of the Breach, and the identity of who accessed and received the Unsecured PHI; iii. a description of the types of unsecured PHI involved in the Breach (e.g., names, social security number, date of birth, address(s), account numbers of any type, disability codes, diagnostic and/or billing codes and similar information); iv. a brief description of what the Associate has done or is doing to investigate the Breach, mitigate harm to the Individual impacted by the Breach, and protect against future Breaches; and v. contact procedures for individuals to ask questions or learn additional information, which shall include a toll-free telephone number, an e-mail address, Web site, or postal address. b. Following a Breach, Associate will have a continuing duty to inform MARICOPA COUNTY of new information learned by Associate regarding the Breach, including but not limited to the information described in items (i) through (v), above. c. Associate also will report in writing to MARICOPA COUNTY any Security Incident (successful or attempted) of which Associate becomes aware within fifteen (15) business days of Associate learning of such Use or Disclosure. Associate will report to MARICOPA COUNTY any unauthorized Access, Use, Disclosure, modification, or destruction of ePHI or interference with system operations in an information system containing ePHI of which Associate becomes aware within fifteen (15) days: i. If the definition of “Security Incident” under the Security Standards is amended to remove the requirement for reporting “unsuccessful” attempts to Use, Disclose, modify or destroy ePHI, the portion of this Section 5 addressing the reporting of unsuccessful, unauthorized attempts will no longer apply as of the effective date of such amendment. 6. Obligations Regarding Associate Personnel. Associate will require all of its agents, and Contractors, subcontractors, or agents of Associate (“Associate Personnel”), whose services may be used to satisfy Associate’s obligations under the Contract or Engagement Letter and this Agreement, to adhere to the same restrictions and conditions with respect to such PHI that apply to the Associate pursuant to of the terms of this Agreement. 7. Access to Protected Health Information. a. MARICOPA COUNTY Access. If, and to the extent that Associate maintains a Designated Record Set of MARICOPA COUNTY, within fifteen (15) business days of receipt of a written request by MARICOPA COUNTY for Access to PHI received from MARICOPA COUNTY, Associate will make requested PHI available to MARICOPA COUNTY. b. Patient Access. If a Patient requests Access to PHI directly from Associate, Associate will within direct the Individual to contact MARICOPA COUNTY directly. MARICOPA COUNTY will be responsible for making all determinations regarding the grant or denial of a Patient’s request for PHI and Associate will make no such determinations. Only MARICOPA COUNTY will release PHI to the Patient pursuant to such a request. 8. Amendment of Protected Health Information. a. MARICOPA COUNTY Request. If, and to the extent that Associate maintains a Designated Record Set of MARICOPA COUNTY, within fifteen (15) business days of receiving a written request from Maricopa County Business Associate Agreement 4 4/3/2015 MARICOPA COUNTY to amend an Individual’s PHI received from MARICOPA COUNTY, Associate will provide such information to MARICOPA COUNTY for amendment and incorporate any such amendments in the PHI (for so long as Associate maintains such information in the Designated Record Set) as required by 45 C.F.R. 164.526. Alternatively, if MARICOPA COUNTY’s written request includes specific information to be included in the PHI as an amendment, Associate will incorporate such amendment within fifteen (15) business days of receipt of the MARICOPA COUNTY’s written request. b. Individual Request. If an Individual makes a request for amendment directly to Associate, Associate will direct the Individual to contact MARICOPA COUNTY directly. MARICOPA COUNTY will be responsible for making all determinations regarding amendments to PHI and Associate will make no such determinations. 9. Accounting of Disclosures; Requests for Disclosure. a. Disclosure Records. Associate will keep a record of any Disclosure of PHI received from MARICOPA COUNTY that Associate makes to its employees, subcontractors, and agents, or other third parties other than: (1) Disclosures to health care providers to assist in the treatment of patients; (2) Disclosures to others to assist MARICOPA COUNTY in paying claims; (3) Disclosures to others to assist MARICOPA COUNTY in conducting its health care operations, as defined in 45 C.F.R. § 164.501; or (4) Disclosures made pursuant to an individual’s Authorization. Associate will maintain this Disclosure record for a period of six (6) years prior to the date on which the accounting is requested. Associate also agrees to maintain necessary and sufficient documentation of Disclosures of Protected Health Information as would be required for MARICOPA COUNTY to respond to a request by an Individual for an accounting of Disclosures, in accordance with 45 CFR 164.528. b. Data Regarding Disclosures. For each Disclosure for which it is required to keep a record under paragraph 8(a), Associate will record and maintain the following information: (1) The date of Disclosure; (2) The name of the entity or person who received the PHI, and, the address of such entity or person, if known. (3) A description of the PHI disclosed; and (4) A brief statement of the purpose of the Disclosure. c. d. Patient Request to Associate. If a Patient requests an accounting of Disclosures directly from Associate, direct the Individual to contact MARICOPA COUNTY directly. MARICOPA COUNTY will be responsible to prepare and for delivery of the records of Disclosure to the Patient. Associate will not provide an accounting of its Disclosure directly to the Individual. 10. Obligations of MARICOPA COUNTY a. Notice of Privacy Practices. MARICOPA COUNTY shall provide Associate a copy of its Notice of Privacy Practices (“Notice”) in accordance with 45 C.F.R. § 164.520 as well as any changes to the Notice. If Maricopa County Business Associate Agreement 5 4/3/2015 MARICOPA COUNTY’ Notice specifically affects Associate’s Use or Disclosure of PHI, MARICOPA COUNTY shall inform Associate of the specific limitations. Associate shall abide by the limitations of MARICOPA COUNTY’ Notice that affects its Use or Disclosure of PHI of which it has been specifically informed. Any use or disclosure permitted by this Agreement may be amended by changes to MARICOPA COUNTY’ Notice if MARICOPA COUNTY specifically informs Associate of the amendment: provided, however, that the amended Notice shall not affect permitted uses and disclosures on which Associate relied prior to receiving notice of such amended Notice. b. MARICOPA COUNTY agrees to timely notify Associate, in writing, of any arrangements, or changes in arrangements, between the MARICOPA COUNTY and the Individual that is the subject of PHI that may impact in any manner the Use and/or Disclosure of that PHI by Associate under this Agreement. c. MARICOPA COUNTY shall not request Associate to Use or Disclose PHI in any manner that would not be permissible under HIPAA if done directly by MARICOPA COUNTY. d. MARICOPA COUNTY represents that, to the extent MARICOPA COUNTY provides PHI to Associate, such PHI is the minimum necessary PHI for Associate to perform its obligations under the underlying Contract(s). e. MARICOPA COUNTY represents that, to the extent MARICOPA COUNTY provides PHI to Associate, MARICOPA COUNTY has obtained the consents, authorizations and/or other forms of legal permission required under HIPAA and other applicable law. 11. Access to Books and Records. a. Government Access. Associate will make its internal practices, books, and records relating to the Use and Disclosure of PHI received from, or created or received by Associate on behalf of, MARICOPA COUNTY available to the Secretary of the Department of Health and Human Services, in a time and manner designated by the Secretary, to the extent required for determining MARICOPA COUNTY’s compliance with the Privacy Standards. 12. To the extent Associate is engaged by the MARICOPA COUNTY to carry out one or of MARICOPA COUNTY’s obligation(s) under Subpart E of 45 C.F.R. Part 164, Associate agrees to comply with the requirements of Subpart E that apply to the MARICOPA COUNTY in the performance of such obligation(s). 13. Termination. Should either Party become aware of a pattern of activity or practice of the other Party that constitutes a material breach of this Agreement, the non-breaching Party shall provide the breaching Party with written notice of such breach in sufficient detail to enable the breaching Party to understand the specific nature of the breach. The non-breaching Party terminate the Contract associated with such breach and this Agreement, if upon written notice to the breaching Party the non-breaching Party fails to cure the breach within a reasonable amount of time not less than thirty (30) days of the date of such notice; provided, however, that such time period specified by the non-breaching Party shall be based on the nature of the breach involved. 14. Return or Destruction of Protect Health Information. a. Return of PHI; Destruction. Upon termination of the Contract, Associate will return to MARICOPA COUNTY and destroy, if feasible, any and all PHI received from MARICOPA COUNTY or created or received by Associate on behalf of MARICOPA COUNTY pursuant to the Contract that Associate maintains in any form or format. Associate will not maintain or keep in any form or format any portion or copies of such PHI. The requirement to return or destroy such PHI will apply to all agents or subcontractors of Associate. Associate will be responsible for recovering any PHI from such agents or subcontractors. Maricopa County Business Associate Agreement 6 4/3/2015 b. Alternative Measures. Upon termination of the Contract for a material breach, if Associate reasonably determines that returning or destroying PHI is infeasible, , Associate shall: 1. Retain only that Protected Health Information which is necessary for Associate to continue its proper management and administration or to carry out its legal responsibilities; 2. Return to MARICOPA COUNTY the remaining Protected Health Information that the Associate still maintains in any form; 3. Continue to use reasonable and appropriate safeguards and comply with Subpart C of 45 CFR Part 164 with respect to Electronic Protected Health Information to prevent Use or Disclosure of the Protected Health Information, other than as provided for in this Section, for as long as Associate retains the Protected Health Information; 4. Not Use or Disclose the Protected Health Information retained by Associate other than for the purposes for which such Protected Health Information was retained and subject to the same conditions set out above in section 1, “Uses and Disclosures of Protected Health Information,” and section 2, “Associate Use or Disclosure of Protected Health Information for its Own Purposes,” which applied prior to termination; and 5. Return to MARICOPA COUNTY the Protected Health Information retained by Associate when it is no longer needed by Associate for its proper management and administration or to carry out its legal responsibilities. 6. The obligations of Associate under this Section shall survive the termination of this Agreement. Restrictions on Use or Disclosure of Protected Health Information. If MARICOPA COUNTY advises Associate, in writing, of any changes in, or restrictions to, the permitted Use or Disclosure of PHI received from MARICOPA COUNTY, Associate will restrict the Use or Disclosure of such PHI consistent with the MARICOPA COUNTY instructions. 15. Mitigation Procedures. Associate agrees to have procedures in place for mitigating, to the maximum extent practicable, any deleterious effect from the Use, loss or Disclosure of PHI received from MARICOPA COUNTY in a manner contrary to this Agreement. 16. Compliance with the HITECH Act. Associate will comply with the requirements of Title XII, Subtitle D of the Health Information Technology for Economic and Clinical Health (HITECH) Act, codified at 42 U.S.C. §§ 17921- 17954, which are applicable to Associates, and will comply with all regulations issued by the Department of Health and Human Services (HHS) to implement these referenced statutes, as of the date by which Associates are required to comply with such referenced statutes and HHS regulations. a. Associate will also comply with Section 13402 of the HITECH Act, codified at 42 U.S.C. § 17932, and with all regulations issued by HHS to implement this statute, as of the date by which Associates are required to comply with such referenced statutes and HHS regulations 17. Miscellaneous. a. Compliance with Laws. The Parties acknowledge that state and federal laws relating to electronic data security and privacy are rapidly evolving and that amendment of this Agreement may be required to ensure compliance with such developments. Should such developments occur, and upon either Party’s good faith request, the other Party agrees to enter good faith negotiations from time to time concerning the terms of an amendment to this Agreement. b. Construction of Terms. The terms of this Agreement will be construed in light of any applicable interpretation or guidance on the Privacy Standards and Security Standards issued by the Department of Health and Human Services and other applicable state or federal laws, rules and regulations as amended from time to time. Maricopa County Business Associate Agreement 7 4/3/2015 c. No Third Party Beneficiaries. Nothing in this Agreement will confer upon any person other than the Parties and their respective successors or assigns, any rights, remedies, obligations, or liabilities, whatsoever. d. Assignment of Rights and Delegation of Duties. This Agreement is binding upon and inures to the benefit of the Parties hereto and their respective successors and permitted assigns. However, neither Party may assign any of its rights or delegate any of its obligations under this Agreement without prior written consent of the other Party, which consent shall not be unreasonable withheld or delayed. Notwithstanding any provisions to the contrary, however, each Party retains the right to assign or delegate any of its rights and obligations hereunder to any of its wholly owned subsidiaries, affiliates or successor companies. Assignments made in violation of this provision are null and void. e. No Waiver. Failure or delay on the part of either Party to exercise any right, power, privilege or remedy hereunder shall not constitute a waiver thereof. No provision of this Agreement may be waived by either Party except by a writing signed by an authorized representative of the Party making the waiver. f. Severability. The provisions of this Agreement shall be severable, and if any provision of this Agreement shall be held or declared to be illegal, invalid or unenforceable, the remainder of this Agreement shall continue in full force and effect as though such illegal, invalid or unenforceable provision had not been contained herein. g. Entire Agreement. This Agreement constitutes the entire agreement between the Parties with regard to the Privacy Standards and Security Standards, there are no understandings or agreements relating to this Agreement that are not fully expressed in this Agreement and no change, waiver or discharge of obligations arising under this Agreement will be valid unless in writing and executed by the party against whom such change, waiver or discharge is sought to be enforced. h. Written Agreement. This Agreement is considered as an integral part of the Underlying Contract(s), and is incorporated as though fully set forth within the Contract. In the event of a conflict between this Agreement and an Underlying Contract, this Agreement shall prevail to the extent necessary to allow the MARICOPA COUNTY and Associate to comply with HIPAA. Except as supplemented and/or amended by this Agreement, the terms of an Underlying Contract shall continue unchanged and shall apply with full force and effect to govern the matters addressed in the underlying Contract. i. Choice of Law. This Agreement and the rights and obligations of the parties hereunder shall be governed by and construed under the laws of the State of Arizona, without regard to applicable conflict of law principles. j. Counterparts. This Agreement may be executed in two or more counterparts, each of which shall be deemed an original and when taken together shall constitute one agreement. k. Independent Contractors. None of the provisions of this Agreement are intended to create, nor will be deemed to create, any relationship between the Parties other than that of independent contracting parties with each other solely for the purposes of affecting the provisions of this Addendum and any other agreements between the Parties evidencing their business relationship. l. Facsimile and Electronic Signatures. Facsimile and electronic signatures shall be deemed to be original signatures for all purposes of this Agreement. m. Notices. Any notices required under this Agreement will be sent to the parties at the following address by first class mail, fax or hand delivery: MARICOPA COUNTY GE Healthcare Maricopa County Business Associate Agreement 8 4/3/2015 BOARD OF SUPERVISORS 301 W. Jefferson Street, 10th Floor Legal Compliance Department Phoenix, AZ 85003 Attn: Senior Privacy Counsel, USCAN Privacy Leader (602) 506-3416 9900 W. Innovation Drive Wauwatosa, WI 53226 GEHCBAA@ge.com Agreed to by MARICOPA COUNTY and Associate by: MARICOPA COUNTY GE HEALTHCARE BY AND THROUGH ITS DEPARTMENT OF PUBLIC HEALTH Digitally signed by Cathy _____________________________________ _________________________________ SIGNATURE DATE SIGNATURE Kaphingst DATE Date: Bill Gates, Chairman, Board of Supervisors 2019.06.12 PRINT NAME AND TITLE PRINT NAME AND TITLE 07:24:54 -05'00' ATTEST: _____________________________________ Office of the Clerk of the Board Date APPROVE AS TO FORM: _____________________________________ Attorney for Maricopa County Date Maricopa County Business Associate Agreement 9 4/3/2015 Schedule A Covered Entity: MARICOPA COUNTY None Maricopa County Business Associate Agreement 10 4/3/2015