Lexology June 20, 2024
There appears to be significant confusion regarding the application of the Health Insurance Portability and Accountability Act (HIPAA) to financial institutions when serving health care provider and health plan clients. If a bank or other financial institution performs functions beyond the routine payment processing activities excepted by HIPAA, it may be a HIPAA business associate, which carries important compliance obligations as a matter of law. Because we are receiving more questions from financial institution clients on this issue, we are updating our prior client alert (found here) and providing a reminder that financial institutions may be subject to serious penalties due to inadvertent HIPAA non-compliance.
Generally, HIPAA only applies to “covered entities” (e.g., health care providers, health plans, and health...
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