Business Procedures Manual

Fiscal Affairs Division

26.3 Designation of HCC Workforce Members

(Last Modified on November 14, 2019)

Those employed in the following areas of the USO or any USG Institution shall be considered HCC Workforce Members and part of the HCC when performing business, legal, financial, administrative or other functions that require the use of and/or disclosure of PHI:

  • Business Operations;
  • Legal Affairs;
  • Institutional Review Boards (IRBs);
  • Any Health Sciences colleges or programs of study and associated services;
  • Information Resources and Communications;
  • Human Resources;
  • Technology Support; and
  • Any other USG employee that performs functions on behalf of entities within the HCC that requires creating, receiving, maintaining, transmitting or storing PHI as defined under HIPAA.

When the same Workforce Members perform functions on behalf of non-covered entities within USG, these functions are not performed on behalf of the HCC and are not covered by HIPAA. Workforce Members must never disclose PHI outside the HCC without the patient’s authorization or as otherwise allowed or required by applicable laws, regulations, and policies.

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