One Trading Partner agreement is all that is necessary for the HIPAA Officer to write. It would be acceptable for any business partner that trades protected health information with them.
The statement is not entirely accurate. The HIPAA Privacy Rule requires covered entities (such as healthcare providers, health plans, and healthcare clearinghouses) to have a written agreement, known as a Business Associate Agreement (BAA), with their business associates who will receive, access, or use protected health information (PHI) on their behalf.
The BAA is a contract between a covered entity and its business associate that establishes the permitted uses and disclosures of PHI by the business associate, the safeguards that the business associate will implement to protect the privacy and security of the PHI, and the business associate’s obligations with respect to PHI under HIPAA.
While it is important for a covered entity’s HIPAA Officer to ensure that they have a BAA in place with all of their business associates, a single BAA may not be sufficient for all business partners. Covered entities must have a BAA in place with each of their business associates who create, receive, maintain, or transmit PHI on their behalf, in order to comply with the HIPAA Privacy Rule.
Therefore, the correct statement is that a HIPAA Officer must write a Business Associate Agreement with each business partner that trades protected health information with them, rather than a single agreement being sufficient for all partners.