First it depends...
Lela "Annie" Goldwyn, MS, CHC, CPC, CPMA
Senior Compliance Analyst, CUMG
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Just curious... why would it matter if the school is a CE? HIPAA allows us to share information with those who are not CEs for certain purposes. So, even if the student health record the school has is covered under FERPA, the information the provider would share is still covered under HIPAA. Would that be a fair statement? If not, where am I going wrong?