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Washington State University Compliance and Civil Rights

Polices, Templates and Assessments

Executive Policy: HIPAA Hybrid Entity 


This policy identifies Washington State University (WSU) as a hybrid entity and designates its covered health care components, which include business associate functions (collectively “Health Care Components” or “HCC”), in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), as amended by the Health Information Technology for Economic and Clinical Health (HITECH) Act.


Policy Templates

These templates are for WSU Departmental use as the groundwork for departmental polices regarding HIPAA and Protected Health Information – Departments needing assistance or that have questions are encouraged to reach out.

Notice of Privacy Practice – Template 

Risk Assessment

Multiple Risk Assessments are available for use ranging from isolated incidents to yearly departmental review.

The Security Risk Assessment Tool provided by the Office of the National Coordinator for Health Information Technology is available for WSU Health Care Components when competing their annual departmental risk assessment.
The SRA tool must be downloaded and installed to use, departments may need to work with their IT contacts for setup. 

Business Associate Agreements

WSU Departments who are considered covered entities must ensure that HIPAA Business Associate Agreements (BAA’s) are in place and up to date with partners regarding Protected Health Information (PHI) security as well as HIPAA compliance.

BAA’s need to go through the WSU Contracts process and procedure as outlined in BPPM 10.11 

WSU Business Associate Decision Tree

WSU – Business Associate Agreement Decision Tree PDF