Old Mill Billing Co.
Former billing service, replaced by Northgate. Billing or coding service. Full patient records.
Findings (1)
Plain rules over the facts below. Fix the fact and the finding clears.
- High findingTerminated vendor, data return not confirmed
No return or destruction has been confirmed.
Fix it under End of the relationshipNext step: Ask the vendor for a certificate of return or destruction, then record it under End of the relationship.
Owner: Keisha Okafor
Draft a request to the vendor
Sending this does not clear the finding. Record the signed BAA, report, confirmation or certificate on this page once the vendor sends it.
Subject: Return or destruction of patient information: Old Mill Billing Co. Hello Old Mill Billing Co. team, Our relationship with Old Mill Billing Co. ended on Aug 17, 2026. Please confirm in writing that all patient information you held for Ridgeline Health Partners has been returned to us or destroyed, and send a certificate of return or destruction that states the date. If returning or destroying any of it is not feasible, tell us what you still hold and confirm that the protections of our business associate agreement continue to apply to it for as long as you do. Thank you, Marisol Vance Compliance Officer, Ridgeline Health Partners
No incident contact email is on file; copy it into a letter or email.Why this matters
When a relationship ends, the vendor must return or destroy our patient data, or extend protections if neither is feasible. Without a certificate there is no evidence it happened.
Business associate agreement
- Document
- Signed Apr 15, 2021
- Filed at
- BAA-019, archived
- Effective
- Apr 15, 2021
- Ends
- Aug 17, 2026
- Next BAA review
- Not set
- Breach notice
- 30 days
- YesBreach reported within 60 days of discovery
- YesWe can terminate if the vendor violates a material term
- YesData is returned or destroyed when the relationship ends
- YesSubcontractors are bound by the same terms
Signed BAA history
- Signed Apr 15, 2021, entered Apr 15, 2021: effective Apr 15, 2021, ends Aug 17, 2026. BAA-019, archived
Risk tier
Score 9. Reviewed every 6 months at this tier.
- Can reach full patient records+4
- Billing or coding service carries high inherent risk+2
- No current SOC 2 report or HITRUST certification+2
- No security questionnaire in the last 12 months+1
Before any security evidence points (patient data access, kind of service, remote access and subcontractors) the score is 6, which is high. That part alone decides whether a SOC 2 report or HITRUST certification is required.
8 and up is critical, 5 to 7 high, 2 to 4 moderate, below 2 low. A vendor without patient data is never above moderate. How the score works
Security evidence
The security questionnaire is the vendor's own answers about how it protects data. A SOC 2 report or HITRUST certification is an outside auditor's report on how well the vendor protects data, rather than the vendor's own answers.
- Out of date
Security questionnaire
Dated Feb 13, 2025, valid to Feb 13, 2026
- None on file
SOC 2 Type II report
Valid for 12 months once received
- None on file
HITRUST certification
Valid for 24 months once received
Subcontractors
Companies this vendor passes our data to.
None recorded.
Data, access and contacts
- Patient data
- Full patient records
- Remote access
- No
- Internal owner
- Keisha Okafor
- In the register since
- Apr 15, 2021
- Contract held by
- Ridgeline Management Services
- Sites served
- Every site
- Patient data first shared
- Not held when the relationship ended
- Data handled
- Claims, charges and billing codes; Insurance and member IDs; Names, contact details and demographics
- Who to call about an incident
- Not recorded
Annual reviews
Terminated vendors are no longer reviewed.
End of the relationship
- Terminated
- Aug 17, 2026
- Our data
- Not yet confirmed
- Certificate
- None on file
Documents (2)
Copies anyone checking can open: signed BAAs, security reports, questionnaires and certificates. Newest first. Attached copies are never removed.
- Security questionnaireSecurity questionnaire (sample). Attached Feb 13, 2025 by Marisol Vance.Open the copy
- Signed BAASigned BAA (sample). Attached Apr 15, 2021 by Marisol Vance.Open the copy
Attach a document
Notes (1)
What happened with this vendor, in order, with who wrote each note and when. Notes are never edited; a correction is a new note.
Contract ended. They still hold five years of claim history.
At intake, Apr 15, 2021
Add a note
History of this record
Recorded automatically when anything changes. Nobody can edit it.
- Marked Old Mill Billing Co. as terminatedMarisol Vance, Aug 17, 2026