What is HCTCs HIPAA status?
After consultation with the Office of Civil Rights (OCR) and the Centers for Medicare and Medicaid Services (CMS), it was determined that the HCTC Program is not a “covered entity” under the Administrative Simplification rules of HIPAA. The HCTC Program also is not considered a business associate to health plan administrators participating in the Program, nor are health plan administrators acting as business associates to the HCTC Program.
