By September 23, 2013, covered dental practices must update all business associate agreements that were entered into on or after January 25, 2013.
By September 22, 2014, covered dental practices must update all business associate agreements that were entered into on or before January 24, 2013 and that were not modified or renewed after that date (if they were modified or renewed, the September 23, 2013 date applies).
Evergreen contracts: if a business associate agreement is entered into on or before January 24, 2013, and it is not modified after that date, but it renews automatically without any change in terms, it must be updated by September 22, 2014.
Oral agreements: if a dental practice does not have a written business associate agreement in place with a business associate, the dental practice must enter into a compliant written agreement without delay.