Pamela J. Bernard, Vice President and General Counsel
The Health Insurance Portability and Accountability Act (HIPAA), a federal law passed in 1996, requires certain entities like the University of Florida to develop and implement procedures regarding electronic healthcare transactions and privacy and security of health data. The University has hired a Privacy Officer, who is housed in the Health Sciences Center where most HIPAA activity will occur. The Privacy Officer is in the process of determining what programs or services at the University will be subject to HIPAA so that all units on campus can comply with the law. Dianne Farb of my office will serve as the liaison between non-health center programs and the University’s new Privacy Officer. This structure will enable non-health center units determined to be subject to HIPAA to have a resource person in this office with whom to discuss HIPAA issues.
In order to determine which campus units will be subject to HIPAA, it is necessary that you forward copies of this memorandum to your respective deans with a request that they or their designees answer the following questions.
QUESTIONS FOR UNITS UNDER YOUR AREA OF RESPONSIBILITY
Do you have programs that provide medical or health care:
Clinical/medical social worker services?
Medical nutrition therapy services?
Physical/occupational therapy services?
Exercise physiology services?
Medical screenings including cancer, mammography, glaucoma, or bone density?
Surgical dressings, casts, and splints?
Leg, arm, back, or neck braces?
If you provide any of the above services, do you file health insurance claim forms for those services?
Do you have programs which conduct human subject research involving treatment which must be approved by the University’s IRB?
If the answer to any of these questions is yes, please have the appropriate person in the college or program contact Dianne Farb, Office of the Vice President & General Counsel, at 392- 1358 or firstname.lastname@example.org no later than September 30th. With your assistance, we can help all units under your areas of responsibility to comply with the law.