Hybrid Covered Entity Designation

The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) permits an organization that engages in both HIPAA covered and non-covered functions to designate itself as a hybrid covered entity.  As a hybrid covered entity, the organization is permitted to place areas which engage in activities regulated under HIPAA into a health care component.  The areas inside the health care component must follow HIPAA regulations; however, the areas which are outside the health care component are not bound by HIPAA regulations. 

The University of Louisville has designated itself as a hybrid covered entity.  The following areas have been designated to be within the University of Louisville health care component. 

  • Campus Health Services (excludes the  Prevention, Education, and Advocacy on Campus and in the Community (PEACC) Program and the Health Promotion Program) - subdivision of services provided to non-students  
  • Department of Athletics - subdivision which processes the level-funded insurance plan offered to student athletes
  • Department of Audit Services
  • Department of Environmental Health & Safety
  • Department of Risk Management
  • Department of University Advancement/Development – subdivision which performs fundraising activities
  • Human Resources - subdivisions which process employee health plan (e.g., Benefits; Total Rewards program)
  • Information Security Compliance Office
  • Information Technology Services
  • Office of Communications & Marketing
  • Office of Finance/Controller – subdivisions of the Controller’s Office which process health care related payments
  • Office of University Counsel
  • Procurement Services – ProCard staff only
  • School of Dentistry and affiliated Institutes and Centers (includes research activities)
  • School of Medicine – clinics/divisions listed below  (NOTE:  excludes research activities and clinics/physician practices that are owned/operated by University of Louisville Health)
    •      Dept of Pathology - Forensic Pathology
    •      Division of Infectious Disease - 550 Clinic
    •      Division of Infectious Disease - International Travel, Refugee Health & Immunization
    •      Division of Infectious Disease - University of Louisville Infectious Disease Laboratory
    •      Division of Infectious Disease -  Civil Surgeon Clinic
  •  University Archives & Records – the subdivision which handles and/or stores protected health information
  •  University Integrity & Compliance Office
  •  University Privacy Office





 Revised/Reviewed January 2023