Comments sought on HIPAA and gifts that support projects policies

Two draft policies — on gifts that support projects and on University HIPAA rules — are currently open for review and comment by faculty, staff and students with Pitt log-in credentials through Nov. 22.

Gifts that support projects

This would be a new University policy established to govern the appropriate administration of gifts made to Pitt to support projects, according to Tom Hitter, assistant vice chancellor for policy development and management.

The new policy would provide clarity on how a specific project is categorized as either a “sponsored project” or a “gift-supported project” to ensure the proper administration between the Office of Research and Office of Philanthropic and Alumni Engagement for those types of funds from third parties wishing to support a University project. The new policy also would provide guidance for University members and donors wishing to pursue this type of funding.

This policy is separate from the recently approved Gift Acceptance and Naming Policy, which Hitter said is broader in scope, as it establishes the standards and requirements for the acceptance of gifts, including those made toward naming. It also says that the Office of Philanthropic and Alumni Engagement is authorized to oversee and administer the University's review, acceptance and processing of gifts. 

HIPAA policy

According to the policy draft, the University is considered a hybrid entity under the Health Insurance Portability and Accountability Act (HIPAA), which says covered entities must describe how they may use and disclose protected health information and their duties to protect privacy and provide a notice of privacy practices. If you’ve gone to a doctor in the past several years, you’ve probably had to sign that you’ve read their HIPAA privacy policies.

Pitt’s privacy officer routinely identifies specific units that need to meet specific standards under HIPAA in the delivery of health care, paying for health care, and providing operational support for health care services.

This policy outlines the responsibilities of the Pitt units covered by HIPAA to provide notice of their privacy policy and training surrounding it, along with several other related issues.

— Susan Jones


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