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POL 2.265 Policy Declaring HIPPA Hybrid Entity Status

Kirtland Community College (“College”), based upon its self-administration of certain uninsured health plans, is a covered entity under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). As its business activities include both covered and, primarily, non-covered functions, it has decided to designate itself as a “hybrid entity” under HIPAA.

As a hybrid entity, the college is divided into covered components and non-covered components. The college hereby designates the following as covered components within the hybrid entity:

  • Medical Service Deductible and Prescription Co-Pay Reimbursement Plan (“Plan”).
  • College business services office, insofar as office personnel provide plan administrative support.

The terms used in this policy have the same meaning as those in HIPAA, the regulations at CFR Parts 160, 162, and 164, and as provided in the college’s HIPAA policy. The requirements of HIPAA, and College policy in that regard, apply only to the covered components included within the hybrid entity.

Approved March 5, 2004