How does HIPAA apply to the University of Miami?
For the purposes of HIPAA, the University of Miami Miller School of Medicine has been designated a “hybrid entity”, one which performs both “covered” and “non-covered” functions. “Covered” functions are those which involve creating and/or receiving patient health information for the purposes of treatment and payment activities, and health care operations. The University’s health care component performs “covered” functions and is therefore subject to HIPAA regulations.
The University of Miami employer-sponsored health plans have been designated a separate covered entity under the regulation.