Answer:
No. A CSP is not a business associate if it receives and maintains (e.g., to process and/or store) only information de-identified following the processes required by the Privacy Rule. The Privacy Rule does not restrict the use or disclosure of de-identified information, nor does the Security Rule require that safeguards be applied to de-identified information, as the information is not considered protected health information. See the OCR guidance on de-identification for more information.[1]
