You should be obtaining an authorization. If your agency is not on the lease, and you do not pay the landlord directly, but you provide the landlord with PHI, you do not need a Business Associate Agreement, and the authorization covers the release.
You should be obtaining an authorization. If your agency is not on the lease, and you do not pay the landlord directly, but you provide the landlord with PHI, you do not need a Business Associate Agreement, and the authorization covers the release.