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University has declared
itself a “Hybrid Entity”
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Hybrid Entity option allows
the University to treat its health care components as separate legal
entities with regard to HIPAA compliance and implementation of Privacy
Rule.
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Parts of USC qualify as
Health Care Components (Student Health Center and Speech and Hearing Clinic).
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Coverage extends to
supporting functions that create or receive PHI on behalf of an HCC (e.g.
billing offices, benefits office, business office personnel)
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Extend coverage to
non-covered entities through “business associate” agreements – (e.g.
attorneys
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