Our agency works closely with small businesses in our community to place consumers in work. We do not pay the business owners so we do not have a business relationship with them in the traditional sense of us purchasing goods or services. Do we need a consent/authorization or a business associate agreement to bring a consumer to the interview, or to place a consumer in the business?

It is prudent to get an individual authorization. The mere fact that an individual receives services from a mental health provider does disclose PHI about the person. You do not need a Business Associate Agreement because you do not have a business relationship and the authorization covers the disclosure.

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