Ryan, I think the question is not whether you are a business associate, but
whether you are/should be actually considered part of the covered entity.
You might look into how the university is defining that, and whether you
should be considered part of it. My suggestion is - regardless of how that
ends up being defined - acting as though you are part of it is not a bad
idea. At a minimum, that entails having anyone who handles the medical
records take basic HIPAA training.


-- 
Dwight Wallis, CRM
Multnomah County Records Management & Distribution Services Manager
1620 SE 190th Avenue
Portland, OR 97233
ph: Records- (503)988-3741
ph: Distribution - (503)988-3533, x29131
cell: (503)260-2263
fax: (503)988-3754
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