Can the positions of Privacy Official (or Officer) and Privacy Liaison be combined into one or is it necessary to appoint individuals to each position?
(May 2003) A: The only requirement in the HIPAA privacy regulations with regard to this topic is that each covered entity designate a Privacy Official, who is responsible for the development and implementation of the covered entity’s policies and procedures with regard to PHI. No other provisions are found in HIPAA describing what the precise requirements for that position must be.
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