Ben Are you "Customer is acting as a Covered Entity or Business Associate, to create, receive, maintain or transmit PHI" https://www.hhs.gov/hipaa/for-professionals/faq/513/does-hipaa-apply-to-an-elementary-school/index.html "Generally, no. In most cases, the *HIPAA* Privacy Rule does not apply to an elementary or secondary school because the school either: (1) is not a *HIPAA* covered entity or (2) is a *HIPAA* covered entity but maintains health information only on students in records that are by definition “education records” under *FERPA* and, therefore, is not subject to the *HIPAA* Privacy Rule." ... " For example, if a public high school employs a health care provider that bills Medicaid electronically for services provided to a student under the *IDEA*, the school is a *HIPAA* covered entity and would be subject to the *HIPAA* requirements concerning transactions. However, if the school’s provider maintains health information only in what are education records under *FERPA*, the school is not required to comply with the *HIPAA* Privacy Rule. Rather, the school would have to comply with *FERPA’s* privacy requirements ..." I am not a lawyer, nor do I not play one on TV. R On Tue, Dec 4, 2018 at 2:56 PM Leslie, Ben <[log in to unmask]> wrote: > Is this something that your school has done....or should do? > > -- > Ben Leslie > *Coordinator of Technology* > Battenkill Valley Supervisory Union / Arlington School District > > *Arlington High School* > P: 802-375-2589 ext. 165 > *Fisher Elementary School* > P: 802-375-6409 ext. 261 > > > ----------------------------------------------------------------------- > > Search <http://list.uvm.edu/archives/school-it.html> the SCHOOL-IT Archive > > Manage <http://list.uvm.edu/cgi-bin/wa?SUBED1=SCHOOL-IT&A=1> your > Subscription to SCHOOL-IT > -- Raymond Ballou [log in to unmask] White River Valley School, Royalton Campus https://www.wrvsd.org/ White River Valley High School / South Royalton Elementary 223 South Windsor Street Royalton VT 05068 802-763-7740 x2051 802-763-3233 fax