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4. What new administrative requirements is the University required to implement?

Pursuant to the HIPAA Privacy Regulations, the University, as a covered entity, must:

1. Appoint a privacy official;

2. Develop and implement privacy policies and procedures;

3. Train its workforce;

4. Adopt privacy safeguards;

5. Establish a complaint process for privacy violations;

6. Adhere to a “no retaliation” policy against individuals who submit privacy complaints;

7. Establish sanctions for privacy violations;

8. Mitigate harmful effects of damage from known privacy violations; and

9. Adhere to a policy prohibiting waivers of patient privacy rights.

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