Independent Contractor vs. HIPAA Workforce Member Classification Guide

Modified on Wed, 14 Jun, 2023 at 8:50 AM

We are frequently asked how “1099” workers or a 1099 organization’s workers / “independent contractors” may be classified under HIPAA. We have been asked whether these workers can be classified as “business associates,” or whether they can be classified as HIPAA “workforce” members. This guide covers what options are available and what factors should be taken into consideration when determining how to classify them.


Refer to the attached document for guidance.

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