Is my agency a business associate?
Usually yes, and usually without anybody having decided it. If your agency can see patient information belonging to a practice you work for, you are handling it on their behalf — and that is what the term means.
The three ways it happens by accident.
What follows from it.
An agreement with each practice. Obligations about safeguards, subcontractors and breach notification.
And a duty that does not go away because the work was done by a contractor or a tool.
Do not hold it.
If the forms and the phone line run somewhere you can operate but not read, you are not handling patient information and the question does not arise.
That is what blind mode is for, and it is the reason it is built into the database rather than promised in a contract.
How blind mode works →Start by finding out what your websites are leaking.
A free scan of any practice site tells you in ninety seconds which trackers are loading on pages that collect patient information. No account, no card.