Protected Health Information Policy And HIPAA “Hybrid Entity” Designation

It is the policy of Lewis & Clark College to safeguard protected health information (PHI) within its possession and to comply with applicable laws regarding PHI. In particular, it is College policy to comply with the Family Education Rights and Privacy Act (FERPA) as it applies to safeguarding and using treatment records or education records of College students. It is also College policy to comply with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) within those components of the College that are subject to HIPAA, as designated in this policy.

Because the primary function of Lewis & Clark College is not to provide health care, the College is permitted to designate itself as a “Hybrid Entity,” which allows it to apply HIPAA only to those parts of the College that, if standing alone, would be a “Covered Entity” under HIPAA.

As a Hybrid Entity, the College must identify in writing its health care components for purposes of HIPAA. Health Care Components at Lewis & Clark College are:

  1. Problem Gambling Services Clinic.

All other components of the College are not considered part of a Covered Entity for purposes of HIPAA.

Approval Date

Adopted by the Executive Council, June 16, 2021