University of Memphis HIPAA Hybrid Designation

The Health Insurance Portability and Accountability Act (HIPAA) and its implementing regulations apply to individuals and organizations designated in the law/regulations as covered entities. "Covered Entities" include health plans, health care clearinghouses and health care providers that conduct specified transactions electronically and their business associates.

The University of Memphis is engaged in activities covered under HIPAA as well as activities that are not covered. HIPAA allows organizations such as the University of Memphis to choose to be designated as a "Hybrid Covered Entity".  To be a hybrid entity, the covered entity must identify its components that perform covered functions and designate these components as health care components.  With that designation, the HIPAA regulations apply only to the designated components and do not apply to the non-covered functions.

Designation of Covered Components

The University of Memphis has designated itself as a hybrid entity in accordance with 45 C.F.R. §§ 164.103 and 164.105.  The following areas constitute its covered components for HIPAA purposes:

• Memphis Speech and Hearing Center
• The School of Communication Sciences and Disorders, to the extent that its students, faculty, and staff work in the Memphis Speech and Hearing Center 
• The Applied Behavioral Analysis department to the extent that it provides covered services through the Interprofessional Community Health Clinic
• Office of Legal Counsel to the extent it provides business associate services to covered components
• Information Technology Services to the extent it provides business associate services to covered components
• Internal Audit to the extent it provides business associate services to covered components

The University reserves the right to amend this designation to include additional components as necessary.