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HomeMy WebLinkAboutC22-337 Vail Health Non-Clinical
4838-7517-4049.3
PROFESSIONAL SERVICES AGREEMENT
THIS PROFESSIONAL SERVICES AGREEMENT (“Agreement”) is entered into on _______________
by and between Vail Clinic, Inc. d/b/a Vail Health Hospital, a Colorado nonprofit corporation, (“CUSTOMER”)
and Eagle County, (“CONTRACTOR”).
BACKGROUND
WHEREAS, CUSTOMER desires to retain, and CONTRACTOR agrees to provide, certain professional
services in accordance with this Agreement.
AGREEMENT
NOW THEREFORE, the parties for good and valuable consideration, the receipt of which are hereby
acknowledged, and intending to be legally bound hereby, agree as follows:
1. SERVICES. CUSTOMER hereby engages CONTRACTOR to provide the full range of professional
services described in Section 2 of this Agreement (the “Services”) on a non-exclusive and as needed basis.
CONTRACTOR hereby agrees to provide such Services under the terms and conditions set forth herein.
2. RESPONSIBILITIES OF CONTRACTOR. CONTRACTOR shall:
2.1 Be responsible for providing the Services listed in Exhibit A.
2.2 Be available to provide the Services during Customer’s regular business hours.
2.3 Comply with all security, safety, and other applicable rules, regulations of CUSTOMER when
providing the Services.
2.4 Provide the Services diligently and in a professional and workmanlike manner.
2.5 Provide updates and consult with a designated representative of CUSTOMER regarding the Services
provided and the progress made.
2.6 Immediately remove any on-site person upon CUSTOMER’s request. If the parties cannot agree upon
a mutually acceptable replacement within five (5) business days of the date of notice thereof, then
CUSTOMER may immediately terminate this Agreement.
2.7 Devote such time and effort in the performance of the Services as requested by CUSTOMER.
3. TERM. This Agreement shall be effective from October 1, 2022 through December 31, 2023 or until
CUSTOMER, in its sole discretion, reasonably finds satisfactory completion of the Services and the
acceptance of all Deliverables (as that term is defined in Section 7 hereof), unless otherwise terminated as
provided herein. This Agreement may be extended for up to three additional one-year terms upon written
agreement of the parties. Any amendments or modifications shall be in writing signed by both parties.
4. COMPENSATION.
4.1. For the Services provided under this Agreement, CUSTOMER agrees to pay CONTRACTOR
Zero Dollars ($0).
4.2. CUSTOMER agrees to reimburse CONTRACTOR for all reasonable pre-approved out-of-pocket
expenses (including, without limitation, travel but not travel time) actually incurred by
CONTRACTOR in performing the Services. Such expenses shall be itemized and invoiced to
CUSTOMER on a monthly basis and the invoice shall include copies of paid receipts and shall
not exceed more than five percent (5%) of the total amount paid under Section 4.1
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4.3. CUSTOMER shall pay all undisputed charges within sixty (60) days after receiving a detailed invoice
from CONTRACTOR.
5. TERMINATION. This Agreement may be terminated by either party, at any time, with or without cause,
and without penalty upon thirty (30) days prior written notice. In such an event, CUSTOMER shall only
be liable for payment to CONTRACTOR for Services actually rendered up to the date of termination. Either
party may also immediately terminate this Agreement if the other party: (i) fails to comply with any term
or condition of this Agreement and such failure remains uncured for more than ten (10) days after the date
of notice thereof, or such additional time, if any, as is reasonably necessary to cure such failure; or (ii)
makes an assignment for the benefit of creditors, files a petition or commences any proceeding under any
bankruptcy or insolvency code or law, or has proceeded to wind up or liquidate its business, and such filing,
petition, or proceeding is not dismissed within sixty (60) days after the date of notice thereof.
6. INDEPENDENT CONTRACTOR. CONTRACTOR and CONTRACTOR's employees, subcontractors,
and agents shall at all times and for all purposes, be deemed to be independent contractors and not
employees, subcontractors, or agents of CUSTOMER. This Agreement does not create a joint venture,
partnership, or other similar association between the parties or any of CONTRACTOR’s employees,
subcontractors, or agents. CONTRACTOR and CONTRACTOR’s employees, subcontractors, or agents
shall not represent themselves to be officers, employees, or agents of CUSTOMER and shall not bind
CUSTOMER to any agreement, liability, or obligation of any nature. CONTRACTOR agrees and
understands that Vail Health will not withhold any taxes on behalf of CONTRACTOR, or any of its
subcontractors, employees, or agents.
7. OWNERSHIP AND CONFIDENTIALITY.
7.1. Omitted
7.2. CONTRACTOR agrees that any information and documents including, without limitation, data,
educational materials, materials relating to business, protocols, guidelines, pricing, strategies,
compensation levels, financial information, trade secrets, and technology (collectively, the
“Confidential Information”) concerning CUSTOMER, its patients, affiliates, employees, agents,
or representatives that are submitted under this Agreement or which CONTRACTOR becomes
aware of during the course of its performance hereunder are confidential and proprietary to
CUSTOMER. CONTRACTOR shall hold all Confidential Information in the strictest confidence
and in accordance with applicable laws and regulations as well as CUSTOMER’s policies and
procedures. CONTRACTOR shall obtain no proprietary rights (directly or indirectly) in or to the
Confidential Information. CONTRACTOR shall not disclose the Confidential Information to any
third party without the prior written consent of CUSTOMER unless required by law. Upon the
expiration or termination of this Agreement, for any reason, CONTRACTOR shall promptly turn
over and return to CUSTOMER all Confidential Information (in whatever form or media) or upon
the written direction of CUSTOMER, destroy the Confidential Information.
7.3 CONTRACTOR acknowledges that a breach of the covenants in this Section 7 by
CONTRACTOR will result in irreparable and continuing damage to CUSTOMER for which
there will be no adequate remedy at law. Accordingly, in the event of any such breach,
CUSTOMER shall be entitled to injunctive relief and an order for specific performance with
respect to such breach. CONTRACTOR shall not oppose such relief on the grounds that there is
an adequate remedy at law, and such right shall be cumulative and in addition to any other
remedies at law or in equity (including, without limitation, monetary damages) which
CUSTOMER may have.
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8. INSURANCE. CONTRACTOR shall provide and maintain during the term of this Agreement, or any
renewal term, insurance policies in adequate amounts to support CONTRACTOR’s obligations hereunder.
Such insurance shall, include without limitation, comprehensive general liability insurance (in minimum
amounts of $1,000,000 per occurrence and $3,000,000 aggregate coverage with appropriate tail coverage
if such insurance is “claims made”); errors and omissions insurance (in minimum amounts of $1,000,000
per occurrence and $3,000,000 aggregate coverage with appropriate tail coverage if such insurance is
“claims made”); auto liability policy including owned and non-owned, (in minimum amounts of $1,000,000
combined single limit and $100,000 per incident for uninsured and under-insured motorist; professional
liability insurance, where applicable, in amounts required by the State of Colorado; and workers’
compensation coverage with statutory limits; and employer liability coverage (in minimum amounts of
$1,000,000 per incident and $1,000,000 aggregate coverage). CONTRACTOR’s insurance coverage
hereunder (except for workers’ compensation and professional liability) shall name CUSTOMER as an
“additional insured.” CONTRACTOR shall provide CUSTOMER with a certificate of insurance. The
certificates of insurance shall contain a provision that coverage will not be canceled, non-renewed, or
materially changed without thirty (30) days’ prior written notice to CUSTOMER. CONTRACTOR is
prohibited from accepting service of legal papers on behalf of CUSTOMER, its agents or any CUSTOMER
insured.
9. INDEMNIFICATION - Intentionally omitted.
10. NOTICES. Any notice required to be provided under the terms and provisions of this Agreement shall be
in writing, and shall be deemed to be delivered when deposited in the United States mail, postage prepaid,
certified mail, return receipt requested, or sent by national overnight courier service (e.g., Federal Express,
UPS) and addressed to the respective party at the address set forth below, or at any such address(es) or
person(s) as each may specify by written notice given to the other party in the manner specified herein.
Notwithstanding the above, notices may also be provided by personal delivery and shall be effective upon
actual receipt.
If to CUSTOMER:
Eagle County
Attention: Heath Harmon
550 Broadway
Post Office Box 660
Eagle, CO 81631
Telephone: 970-328-8818
E-Mail: Heath.Harmon@eaglecounty.us
With a copy to:
Eagle County Attorney
500 Broadway
Post Office Box 850
Eagle, Co 81631
Telephone: 970-328-8685
E-Mail: atty@eaglecounty.us
With a copy to:
Emily Weber
Foley & Lardner, LLP
600 17th St., Suite 2020S
Denver, CO 80202
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11. NON-DISCRIMINATION. Each party agrees that, in the performance of this Agreement, services will
be provided without discrimination toward any patients, employees, or other persons regardless of their
race, color, sex, age, religion, national origin, sexual orientation, marital status, or disability or any other
manner prohibited by law.
12. ASSIGNMENT. Neither party shall assign any of its rights or obligations under this Agreement without
the prior written consent of the other party. Any such assignment is expressly prohibited. Notwithstanding
the foregoing, CUSTOMER, however, shall be permitted to assign its rights and obligations under this
Agreement to any other person, entity, or organization affiliated with Vail Health without the consent of
CONTRACTOR. In the event that Vail Health sells, transfers, or devises, all or substantially all of, its
assets or stock, that transfer shall not constitute an assignment hereunder.
31. 13. ENTIRE AGREEMENT. This Agreement constitutes the entire understanding and agreement
between the parties concerning the subject matter hereof. This Agreement supersedes all prior written or
oral agreements or understandings existing between the parties concerning the subject matter hereof. Each
party acknowledges that: (i) it has carefully read this Agreement; (ii) it has had the assistance of legal
counsel of its choosing (or such other professionals and advisors as it deemed necessary) in the review and
execution of this Agreement; (iii) the meaning and effect of various terms and provisions hereof have been
fully explained to it by such counsel; (iv) it has conducted such investigation, review, and analysis as it has
deemed necessary to understand the provisions of this Agreement and the transactions contemplated hereby;
and (v) it has executed this Agreement of its own free will. No amendment to any provision of this
Agreement shall be effective unless in writing and signed by each party.
14. NON-WAIVER. No waiver of any term, provision, or condition of this Agreement, whether by conduct or
otherwise, in any one or more instances, shall be deemed to be or construed as a further and continuing
waiver of any such term, provision or condition of this Agreement. No waiver shall be valid unless in
writing and signed by the parties.
32. 15. GOVERNING LAW. This Agreement shall be construed and interpreted in accordance with, and
its performance governed by, the laws of the State of Colorado. The Parties agree that any and all
proceedings related to the subject matter hereof shall be commenced and maintained in the state courts in
Eagle County, Colorado or the United States District Court for Colorado, which courts shall have exclusive
jurisdiction for such purpose.
33. 16. MISCELLANEOUS. Notwithstanding anything to the contrary contained or implied herein,
compensation payable to CONTRACTOR hereunder shall not be determined in a manner that takes into
account (directly or indirectly) the volume or value of any referrals made by CONTRACTOR.
34. 17. COMPLIANCE. CONTRACTOR shall comply with applicable: (i) federal, state, and local laws,
regulations, and executive orders, and amendments thereto, including, but not limited to, OSHA, NRC and
CDC regulations, Medicare and Medicaid billing and referral regulations, and the Colorado Department of
Health and Colorado Department of Human Services regulations; (ii) accreditation standards; (iii)
requirements imposed under any city, state, federal, foundation or other award, contract, funding,
reimbursement, payments policy, or grant; and (iv) CUSTOMER’s policies and procedures including,
without limitation, its anti-discrimination and sexual harassment policies.
18. FURTHER ASSURANCES. The parties agree to execute such other documents and to perform all such
other and further acts as may be necessary or desirable to carry out the purposes and intent of this
Agreement. In addition, the parties agree to fully cooperate in assisting each other and their duly authorized
employees, agents and attorneys in investigating, defending, or prosecuting incidents involving potential
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claims or lawsuits arising out of or in connection with this Agreement. Nothing in this paragraph shall
require the parties to cooperate in the event of claims or lawsuits against each other.
19. NON-EXCLUSIVITY. Nothing in this Agreement shall be construed to require CUSTOMER to obtain
services from CONTRACTOR on an exclusive basis or to prohibit CONTRACTOR from providing
services to any other third party.
20. BINDING AGREEMENT. All of the terms and provisions of this Agreement shall be binding upon, inure
to the benefit of and be enforceable by each of the parties hereto, their respective legal representatives and
their permitted successors and assigns.
21. BOOKS AND RECORDS. This provision is included herein because of possible application of Section
1861(v)(I)(1) of the Social Security Act (the “Act”) to this Agreement. To the extent that this section of
the Act is applicable, CONTRACTOR agrees to make available upon written request of the Secretary of
Health and Human Services or the United States Comptroller General or any of their duly authorized
representatives, this Agreement, and any books, documents and records of CONTRACTOR that are
necessary to certify the nature and extent of costs incurred by CUSTOMER under this Agreement until the
expiration of four (4) years after the termination or expiration of this Agreement. If CONTRACTOR carries
out any of the duties or obligations contemplated by this Agreement through a contract or subcontract with
a value of Ten Thousand Dollars ($10,000) or more over a twelve (12) month period, such contract or
subcontract shall require this same access to the books, documents, and records of such contractor or
subcontractor.
22. SANCTIONED PERSONS. CONTRACTOR represents and warrants to CUSTOMER that it and any of
its agents, employees, officers, and representatives providing services under this Agreement: (a) are not
“sanctioned persons” under any federal or state program or law; (b) have not been listed in the current
Cumulative Sanction List of the Office of Inspector General for the United States Department of Health
and Human Services for currently sanctioned or excluded individuals or entities; (c) have not been listed
on the General Services Administration’s List of Parties Excluded from Federal Programs; (d) have not
been convicted of a criminal offense related to health care; (e) have not been listed on the United States
Department of Treasury, Office of Foreign Assets Control’s Specially Designated Nationals and Blocked
Persons List; and (f) are not a debarred or suspended contractor of the State of Colorado.
CONTRACTOR shall immediately notify CUSTOMER in the event that CONTRACTOR is no longer
able to make such representations and warranties. Without limitation to any other rights and remedies
under this Agreement, afforded by law, or in equity, CUSTOMER may terminate this Agreement, without
penalty, with five (5) days written notice, in the event that CUSTOMER has determined that
CONTRACTOR is in breach of this provision.
23. CONFLICT OF INTEREST. CONTRACTOR represents and warrants to CUSTOMER that: (a) no
employee (or their spouse, parent, brothers, sisters, or relatives) of CUSTOMER or its affiliates is an
officer, director, trustee, partner, or agent of CONTRACTOR; (b) no employee (or their spouse, parent,
brothers, sisters, or relatives) of CUSTOMER or its affiliates has a five percent (5%) or more interest in
the business of CONTRACTOR; (c) neither CONTRACTOR nor any employee, agent, or representative
of CONTRACTOR shall offer gifts or kick-backs, whether in cash or kind, of any kind or value or solicit
special favors from any CUSTOMER agent or employee (or their spouse, parent, brothers, sisters, or
relatives) of CUSTOMER or its affiliates (including, without limitation, physicians and staff members);
(d) CONTRACTOR’s employees, agents, subcontractors, and representatives shall not participate in
individual deliveries of products or services to any employee (or their spouse, parent, brothers, sisters, or
relatives) of CUSTOMER or its affiliates; and (e) CONTRACTOR, shall immediately reveal to
CUSTOMER any conflicts, or the appearance of a conflict (including, without limitation, recommending
or subcontracting services to an affiliate of CONTRACTOR).
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24. HIPAA. To the extent that this Agreement requires a Business Associate Agreement as defined under the
Health Insurance Portability and Accountability Act of 1996, P. L. 104-191 (the “Act”), the parties
without limitation to its other requirements under HIPAA and other federal, state and local laws and
regulations, agree to comply with the Act, the privacy standards set forth in 45 C.F.R. Parts 160 and 164
(the “Privacy Rule”), the security standards set forth in 45 C.F.R. Parts 160, 162, and 164 (the “Security
Rule”), and the Health Information Technology for Economic Clinical Health Act, Title XIII of Division
A and Title IV of Division D of Pub. L. 111-5 (“HITECH”) and all of the rules and regulations
implemented thereunder. The Act, the Privacy Rule, the Security Rule, and HITECH are collectively
referred to as “HIPAA.” All defined terms under HIPAA shall have the same meaning in this Agreement,
and are incorporated herein by reference. Without limitation to other rights and remedies under the
Agreement or afforded by law, CUSTOMER may upon five (5) business days written notice terminate the
Agreement in the event that it has determined that there is a material breach with this provision. The
parties shall execute additional mutually agreed upon documents, including but not limited to a Business
Associate Agreement, attached as Exhibit B if applicable, as required under HIPAA rules and regulations
to assure the safeguarding of protected health information. In the event such documentation is not agreed
upon and executed, either party may terminate the Agreement with thirty (30) days written notice.
25. SEVERABILITY. If any portion of this Agreement is held invalid or unenforceable by a court decision,
statute, rule, or otherwise, then it shall be deemed modified so as to make it valid and enforceable,
consistent with the parties' manifest intentions, or if it cannot be so modified, shall be deemed stricken
from this Agreement. In either case, the remaining portions of this Agreement shall remain in full force
and effect, unless their enforcement without the stricken provision would be inconsistent with the parties'
manifest intentions.
26. HEADINGS. Any captions or headings contained in this Agreement are inserted only as a matter of
convenience and in no way define, limit, or extend the scope or intent of this Agreement or any provision
hereof.
27. TAXES. The parties acknowledge that CUSTOMER is a non-profit organization exempt from the
payment of Colorado sales and use taxes. CONTRACTOR is responsible for requesting and obtaining all
required tax exemption numbers.
28. SURVIVAL. The provisions of this Agreement that may reasonably be interpreted or construed as
surviving the expiration or termination of the Agreement (including, without limitation, indemnification,
insurance, confidentiality, work product and proprietary rights, books and records, and governing law)
shall so survive.
29. JOINTLY DRAFTED. This Agreement shall be deemed to be jointly drafted by both parties and, in the
event of a dispute, shall not be construed against or in favor of either party on account of its participation
in the drafting hereof.
30. CONFLICTING TERMS. In the event of a conflict between the terms and conditions of any exhibit,
schedule, or other attachment hereto and the terms and conditions of this Agreement, the terms and
conditions of this Agreement shall prevail.
35. AUDIT. During the term of this Agreement and for a period of four (4) years thereafter, CUSTOMER
shall have the right to engage, at its expense, external or internal auditors (collectively the “Auditors”) for
the purpose of performing audits that may be required by CUSTOMER to determine the accuracy and
correctness of accounting, backup procedures, and internal controls performed or maintained by
CONTRACTOR in connection with this Agreement. CONTRACTOR shall cooperate by timely
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4838-7517-4049.3
furnishing such Auditors with any and all information as is reasonably necessary to perform and complete
all audit procedures determined to be necessary by the Auditors. Any such audit will be conducted during
CONTRACTOR’s normal business hours and in such a manner to reasonably avoid undue disruption of
CONTRACTOR’s operations.
36. COUNTERPARTS. Provided that all parties hereto execute a copy of this Agreement, this Agreement
may be executed in counterparts, each of which shall be deemed an original and all of which together
shall constitute one and the same instrument. Executed copies of this Agreement may be delivered by
facsimile transmission or other comparable means.
33. CHANGE OF LAW. Notwithstanding anything contained herein to the contrary, either party may notify
the other in writing of its intention to terminate this Agreement if at any time any federal, state or local
government law, regulation or policy, or the policies of any material third party payor, or interpretations of
the foregoing given by a reputable health care attorney, by virtue of this Agreement, cause either party to
fail to comply with any such law, regulation, policy or interpretation or shall materially impair (impairment
being considered in the legal compliance, operational or financial sense) the continuing validity and/or
effectiveness of any material provision hereof. This termination will become effective only if the parties
in good faith are unable to agree, within thirty (30) days after receipt of notice of such impairment, upon a
modification to this Agreement that will bring the Agreement into compliance with the law, regulation or
policy at issue.
34. AUTHORIZATION. The parties acknowledge that CUSTOMER is authorized to enter into this
Agreement on its own behalf and/or on behalf of its Affiliates. For purposes of this Agreement,
“Affiliates” shall mean those organizations controlling, controlled by, or under common control with
CUSTOMER. CONTRACTOR shall bill CUSTOMER or its designated Affiliates for their respective
use of the Services provided under this Agreement. The rights and obligations of this Agreement shall
apply to each Affiliate. No Affiliate shall be responsible for any act, omission, or financial obligation of
CUSTOMER or any other Affiliate under this Agreement; nor shall CUSTOMER be responsible for any
act, omission, or financial obligation of any Affiliate.
35. Notwithstanding anything to the contrary contained in this Agreement, County shall have no obligations
under this Agreement after, nor shall any payments be made to Contractor in respect of any period after
December 31 of any year, without an appropriation therefor by County in accordance with a budget
adopted by the Board of County Commissioners in compliance with Article 25, title 30 of the Colorado
Revised Statutes, the Local Government Budget Law (C.R.S. 29-1-101 et. seq.) and the TABOR
Amendment (Colorado Constitution, Article X, Sec. 20).
36. The parties hereto understand and agree that the County is relying on, and does not waive or intend to
waive by any provision of this Agreement, the monetary limitations or rights, immunities and protections
provided by the Colorado Governmental Immunity Act, as from time to time amended, or otherwise
available to County, its affiliated entities, successors or assigns, its elected officials, employees, agents
and volunteers.
Signature page follows
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4838-7517-4049.3
IN WITNESS WHEREOF, this Agreement has been executed by each party’s duly authorized representatives
as of the date first written above.
VAIL CLINIC, INC.
By:
Name:
Title:
Date:
CONTRACTOR
COUNTY OF EAGLE, STATE OF COLORADO, By and Through Its COUNTY MANAGER
By: ______________________________
Jeff Shroll, County Manager
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EXHIBIT A
SERVICES
CONTRACTOR shall provide the following services to CUSTOMER:
1. Provide the Family Connects services to families who deliver at the hospital and consent to participation
in the Family Connects program
2. Recruitment of Vail Health patients while at the Family Birthing Center for the Family Connects program
3. Provide training to hospital nurses on key talking points regarding the Family Connects program
4. Provide feedback regarding trends in data regarding Vail Health patients
5. Communicate with Vail Health’s providers as necessary
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EXHIBIT B
VAIL CLINIC INC.
BUSINESS ASSOCIATE AGREEMENT
January 2022 1
HIPAA BUSINESS ASSOCIATE AGREEMENT
This BUSINESS ASSOCIATE AGREEMENT (the “Agreement”) is effective as of date of the
Professional Services Agreement (the “Effective Date”) by and between Vail Health Services and
all affiliated covered entities (Vail Health) and Eagle County (“Contractor”).
Recitals:
WHEREAS, the parties have entered into an agreement (the “Services Agreement”) in
order for Contractor to provide certain services to Vail Health (“Services”) that involve the access,
Use and/or Disclosure of PHI (as defined below) and such PHI will be protected in compliance
with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and its
regulations, as amended by the Health Information Technology for Economic and Clinical Health
Act of the American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5, Title XIII (2009)
(the “HITECH Act”) and its implementing regulations and guidance issued by the Secretary of the
U.S. Department of Health and Human Services (the “Secretary”) (collectively, the “HIPAA
Regulations”); and
WHEREAS, both parties are subject to the HIPAA Regulations, either as a Covered Entity
or a Business Associate, and as such, are required to agree to specific terms that govern the Use
and Disclosure of PHI Disclosed by Vail Health to Contractor in conjunction with the Services
Agreement; and
WHEREAS, the parties wish to enter into this Agreement in order to comply with HIPAA.
NOW, THEREFORE, in consideration of the mutual promises and covenants set forth
below, VAIL HEALTH and Contractor agree as follows:
1. Definitions
(a) General. Capitalized terms used, but not otherwise defined, in this Agreement shall
have the meanings set forth in the HIPAA Regulations.
(b) “Disclose” and “Disclosure” mean, with respect to PHI, the release, transfer,
provision of access to, or divulging in any other manner of PHI outside of Business
Associate or to other than members of its Workforce, as set forth in 45 C.F.R. §
160.103.
(c) “Electronic PHI” or “e-PHI” means PHI that is transmitted or maintained in
electronic media, as set forth in 45 C.F.R. § 160.103.
(d) “Personal Information” shall have the meaning given to such term under Colo. Rev.
Stat. § 6-1-716(1).
(e) “Protected Health Information” and “PHI” mean any information, whether oral or
recorded in any form or medium, provided by Vail Health to Contractor, that: (a)
January 2022 2
relates to the past, present or future physical or mental health or condition of an
individual; the provision of health care to an individual, or the past, present or future
payment for the provision of health care to an individual; (b) identifies the
individual (or for which there is a reasonable basis for believing that the information
can be used to identify the individual); and (c) shall have the meaning given to such
term under 45 C.F.R. § 160.103. Protected Health Information includes e-PHI.
(f) “Required by Law” shall have the meaning given to such term under 45 C.F.R. §
164.103.
(g) “Unsecured PHI” shall have the meaning given to such term under 42 U.S.C. §
17932(h), 45 C.F.R. § 164.402, and guidance issued pursuant to the HITECH Act
including, but not limited to the guidance issued on April 17, 2009 and published
in 74 Federal Register 19006 (April 27, 2009) by the Secretary.
(h) “Use” or “Uses” mean, with respect to PHI, the sharing, employment, application,
utilization, examination or analysis of such PHI within Business Associate’s
internal operations, as set forth in 45 C.F.R. § 160.103.
2. Permitted Uses and Disclosures of Protected Health Information by Contractor
(a) Use or Disclosure of Information. Contractor shall not Use, or Disclose Personal
Information and/or PHI received, created, maintained, or transmitted for or on
behalf of, Vail Health other than to perform the Services described in the Services
Agreement, and as expressly permitted or required by this Agreement or as
Required By Law.
(b) Mitigation. Contractor agrees to mitigate, to the extent practicable, any harmful
effect that is known to Contractor of a Use or Disclosure of PHI by Contractor in
violation of this Agreement.
(c) Safeguards. Contractor shall use appropriate administrative, technical and physical
safeguards and comply with Subpart C of 45 CFR Part 164 to protect the
confidentiality of PHI received from Vail Health to prevent the Use or Disclosure
of PHI other than as provided for in this Agreement.
(d) Reporting.
(i) Contractor agrees to report to Vail Health any Use or Disclosure of personal
information and or Unsecured PHI in violation of the applicable HIPAA
Regulations and Colorado Data Breach Notification Law, including but not
limited to C.R.S. 6-1-716(“Colorado Data Breach Notification Law”), or
this Agreement of which Contractor becomes aware, including, without
limitation, any impermissible or improper Use, Disclosure, Security
Incident or Breach of Unsecured PHI within forty-eight (48) hours of
discovery of same in accordance with Section 6(i), “Notices,” of this
Agreement.
January 2022 3
(ii) Contractor shall provide a written report to Vail Health of such Breach
without unreasonable delay but no later than five (5) business days after
discovery of the Breach. Contractor shall be deemed to have discovered a
Breach as of the first day that the Breach is either known to Contractor or
any of its Workforce or agents, other than the person who committed the
Breach, or by exercising reasonable diligence should have been known to
Contractor or any of its Workforce or agents, other than the person who
committed the Breach. To the extent the information is available to
Contractor, Contractor’s written notice shall include the information
required by 45 C.F.R. §164.410(c). Contractor shall promptly supplement
the written report with additional information regarding the Breach as it
obtains such information. Contractor shall cooperate with Vail Health in
meeting Vail Health’s obligations with respect to such Breach. Vail Health
shall have sole control over the timing and method of providing notification
of such Breach to the affected individual(s), the Secretary and, if applicable,
the media. Contractor shall reimburse Vail Health for its reasonable costs
and expenses in providing the notification, including, but not limited to, any
administrative costs associated with providing notice, printing and mailing
costs, and costs of mitigating the harm (which may include the costs of
obtaining credit monitoring services and identity theft insurance) for
affected individuals whose PHI has or may have been compromised as a
result of the Breach.
(iii) Contractor agrees that if Vail Health determines or has a reasonable belief
that Contractor may have Used, made a Disclosure of, or permitted access
to PHI in a way that is not authorized by this Agreement, then Vail Health
may in its sole discretion require Contractor to: (a) promptly investigate and
provide a written report to Vail Health of Contractor’s determination
regarding any alleged or actual unauthorized Disclosure, access or Use; (b)
cease such practices immediately; (c) return to Vail Health or destroy all
PHI; and (d) take any other action Vail Health deems appropriate, as
required by law or deemed reasonable by both parties.
(e) Subcontractors and Agents. Contractor shall ensure that any agent or subcontractor
to whom it provides PHI agrees to the same restrictions and conditions that apply
to the Contractor under this Agreement with respect to such PHI in its possession.
(f) Access. Contractor agrees to provide access, when requested by Vail Health, to
PHI in such Designated Record Set in order to comply with the requirements under
45 C.F.R. § 164.524. Such access shall be provided by Contractor in the time and
manner reasonably requested by Vail Health or the Individual.
(g) Amendment. When requested by Vail Health, Contractor agrees to make any
amendment(s) to PHI in such Designated Record Set that Vail Health or the
Individual directs or agrees to pursuant to 45 C.F.R. § 164.526. Such amendments
shall be made by Contractor in the time and manner reasonably requested by Vail
Health or the Individual. In the event Contractor receives an amendment request
January 2022 4
directly from an Individual, Contractor shall forward the request to Vail Health
promptly upon receipt.
(h) Audit and Inspection. Contractor agrees to make its internal practices, books, and
records, including policies and procedures relating to the Use and Disclosure of
PHI, available to Vail Health or the Secretary or his or her designee for the limited
purposes of the Secretary determining Vail Health’s compliance with HIPAA, as
requested by Vail Health or the Secretary. Additionally, Vail Health reserves the
right to audit the Business Associate and information security controls and
processes of any associated Service Providers and to perform relevant tests to
ensure that it is compliant with applicable HIPAA information security and privacy
requirements as well as the requirements within this contract. Business Associate
will permit Vail Health to perform an information security audit, including an audit
of technical, physical and administrative security of any applicable Service
Provider premises applicable to the engagement and will cooperate and furnish all
requested materials in a timely manner, within no more than three business days.
(i) Documentation of Disclosures/Accounting. Contractor agrees to document any
Disclosures of PHI and any information related to such Disclosures as would be
required for Vail Health to respond to a request by an Individual for an accounting
in accordance with 45 C.F.R. § 164.528, and upon request by Vail Health, to
provide such information to Vail Health or to the Individual. In the event
Contractor receives an accounting request directly from an Individual, Contractor
shall forward the request to Vail Health immediately upon receipt.
(j) Compliance with Privacy Rule. To the extent that Vail Health is a Covered Entity
and Contractor is performing an obligation of Vail Health under the Privacy Rule,
Contractor shall comply with the requirements of the Privacy Rule that apply to a
Covered Entity in the performance of such obligation.
(k) Other Laws. Contractor understands that Vail Health is subject to State and Federal
laws in addition to HIPAA governing the privacy and security of PHI. Contractor
agrees to abide by all such laws, whether or not fully articulated herein, and to keep
the PHI in the same manner and subject to the same standards as is required of Vail
Health.
3. Permitted Uses and Disclosures
(a) Services. Subject to the provisions of Section 4 below, and except as otherwise
limited in this Agreement, Contractor may Use or Disclose PHI to perform
functions, activities, or services for, or on behalf of, Vail Health or Contractor if
such Use or Disclosure of PHI would not violate HIPAA or the HIPAA
Regulations.
(b) Minimum Necessary. Contractor (and its Subcontractors) shall, to the extent
practicable, limit its request, Use, or Disclosure of PHI to the minimum amount of
PHI necessary to accomplish the purpose of the request, Use or Disclosure, in
January 2022 5
accordance with 42 U.S.C. § 17935(b) and 45 C.F.R. § 164.502(b)(1) or any other
guidance issued thereunder.
(c) Business Activities. Except as otherwise limited in this Agreement, Contractor may
Use and Disclose PHI for its proper management and administration of Contractor
or to meet its legal responsibilities.
4. Obligations of Vail Health
(a) Restrictions. To the extent that such limitations may affect Contractor’s Use or
Disclosure of PHI, Vail Health shall notify Contractor of (i) any limitations in any
applicable notice of privacy practices as required under 45 C.F.R. 164.520, as well
as any changes to that notice, (ii) any changes in, or revocation of, permission by
an Individual to Use or Disclose PHI, and (iii) any restriction to the Use or
Disclosure of PHI agreed to in accordance with 45 C.F.R. 164.522.
(b) Requests. Vail Health shall not request Contractor to Use or Disclose PHI in any
manner that would not be permissible under HIPAA if done by Vail Health.
5. Term and Termination
(a) Term. This Agreement shall be effective as of the Effective Date and shall continue
unless or until the Agreement is terminated in accordance with the provisions of
Section 5(b), or the Agreement between the parties terminates.
(b) Termination for Cause. Upon knowledge of a material breach by either party, either
party shall either (i) provide an opportunity for the other party to cure the breach or
end the violation and, if other party does not cure the breach or end the violation
within the cure period specified in the Agreement or if none is specified, then within
ten (10) days, terminate this Agreement and the Services Agreement; (ii)
immediately terminate this Agreement and the Services Agreement if cure is not
possible; or (iii) if neither termination nor cure are possible, either party shall report
the violation to the Secretary.
(c) Effect of Termination.
(i) Upon termination of this Agreement or the Services Agreement for any
reason, Contractor shall return or destroy all PHI received from Vail Health.
Contractor shall retain no copies of the PHI in any form. Contractor shall
promptly provide written confirmation of such destruction to Vail Health.
(ii) Notwithstanding the foregoing, in the event that Contractor determines that
returning or destroying the PHI is infeasible, Contractor shall provide to
Vail Health notification of the conditions that make return or destruction
infeasible. If the return or destruction of PHI is infeasible, Contractor shall
extend the protections of this Agreement to such PHI and limit further Uses
and Disclosures of such PHI to those purposes that make the return or
destruction infeasible, for so long as Contractor maintains such PHI.
January 2022 6
6. Miscellaneous
(a) Survival. The respective rights and obligations of Contractor under 5(c) and 6(a)
of this Agreement shall survive the termination of this Agreement.
(b) Amendments. No amendment to this Agreement shall be effective unless it is in
writing and signed and dated by the parties hereto or as required by law or
regulations. The parties recognize that the Secretary may issue further amendments
to the HIPAA Regulations pursuant to the Secretary’s authority under law.
(c) Interpretation. Construction of this Agreement shall be resolved in favor of a
meaning that permits both parties to comply with applicable law protecting the
privacy, security and confidentiality of PHI, including but not limited to HIPAA
and the HIPAA Regulations. To the extent that any provisions of this Agreement
conflict with the provisions of any other agreement or understanding between the
parties, this Agreement shall control.
(d) Other Federal and State Law. The parties agree to comply with other federal and
state law as may apply to the Protected Health Information. In the event of a conflict
between the requirements of such other law and the requirements stated herein, the
applicable law under a conflict-of-law analysis, including the preemption analysis
required under HIPAA, shall apply.
(e) Waiver. No failure to exercise and no delay in exercising any right, remedy or
power hereunder shall operate as a waiver thereof, nor shall any single or partial
exercise of any right, remedy or power hereunder preclude any other or further
exercise thereof or the exercise of any other right, remedy or power provided herein
or by law or in equity.
(f) Subpoena. In the event that Contractor receives a subpoena for any PHI in
Contractor’s possession, Contractor shall immediately notify Vail Health and
deliver a copy of the subpoena to Vail Health. Contractor shall respond to the
subpoena only in accordance with the Privacy Rule.
(g) Indemnification. Intentionally Omitted.
(h) No Third-Party Beneficiaries. Nothing express or implied in this Agreement is
intended or shall be deemed to confer upon any person other than Vail Health,
Contractor, and their respective successors and assigns, as permitted pursuant to the
Agreement, any rights, obligations, remedies or liabilities.
(i) Notices. . Any notice required to be provided under the terms and provisions of
this Agreement shall be in writing, and shall be deemed to be delivered when
deposited in the United States mail, postage prepaid, certified mail, return receipt
requested, or sent by national overnight courier service (e.g., Federal Express, UPS)
and addressed to the respective party at the address set forth below, or at any such
address(es) or person(s) as each may specify by written notice given to the other
January 2022 7
party in the manner specified herein. Notwithstanding the above, notices may also
be provided by personal delivery and shall be effective upon actual receipt.
If to CUSTOMER:
Eagle County
Attention: Heath Harmon
550 Broadway
Post Office Box 660
Eagle, CO 81631
Telephone: 970-328-8818
E-Mail: Heath.Harmon@eaglecounty.us
With a copy to:
Eagle County Attorney
500 Broadway
Post Office Box 850
Eagle, Co 81631
Telephone: 970-328-8685
E-Mail: atty@eaglecounty.us
If to Vail Health:
Compliance Officer
P.O. Box 40,000
Vail, CO 81658
E-Mail: Privacy@vailhealth.org
(j) Entire Agreement. This Agreement together with the Services Agreement
constitutes the entire agreement of the parties with respect to the subject matter
hereof, and all prior and contemporaneous understandings, agreements and
representations, whether oral or written, with respect to such matters are
superseded.
(k) Assignment. No assignment of this Agreement or the rights and obligations
hereunder shall be valid without the specific written consent of both parties hereto,
provided, however, that this Agreement, in conjunction with an assignment of the
Services Agreement to the same assignee, may be assigned by Vail Health to any
successor entity operating Vail Health, and such assignment shall forever release
Vail Health hereunder.
(l) Binding Effect. This Agreement shall be binding upon the parties hereto and their
respective heirs, executors, administrators, successors and permitted assigns.
(m) Non-Exclusivity. Nothing in this Agreement shall be construed as limiting the right
of either party to affiliate or contract with any other person or entity on either a
limited or general basis while this Agreement is in effect.
January 2022 8
(n) Signatures. This Agreement may be executed in counterparts, each of which when
so executed and delivered shall be deemed an original and all of which taken
together shall constitute one instrument. This Agreement and any counterpart
original may be executed and transmitted by facsimile. The facsimile signature
shall be valid and acceptable for all purposes as if it were an original.
IN WITNESS WHEREOF, the parties hereto have duly executed this Agreement as of the
Effective Date.
Vail Health:
______________________________
By: __________________________
Title: ________________________
Date: _________________________
CONTRACTOR
COUNTY OF EAGLE, STATE OF COLORADO, By and
Through Its COUNTY MANAGER
By: ______________________________
Jeff Shroll, County Manager