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Committee forwards HIPAA-designation resolution to Board, designates three city departments as health-care components

San Francisco Board of Supervisors Public Safety and Neighborhood Services Committee · September 23, 2021
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Summary

The committee voted 3-0 to send a resolution to the Board designating the Department of Public Health, Fire Department and Health Service System as HIPAA-covered components under Administrative Code Chapter 22H; the designation will standardize policies, training and a periodic three-year review.

The Public Safety & Neighborhood Services Committee on Sept. 23 recommended that the Board of Supervisors approve a resolution accepting the city administrator's report and designating specific city departments as health-care components under HIPAA (the federal Health Insurance Portability and Accountability Act of 1996).

Bill Barnes of the City Administrator's office presented the report and noted a clerical correction (the file in the record dated 2020 should read 2021). He told the committee that the designation implements a hybrid-entity approach for the city: the Department of Public Health, the Fire Department (through emergency medical services) and the Health Service System (which provides insurance to city employees and retirees) will be HIPAA-covered components, while other departments will function as business associates when they need protected health information for billing, legal advice, or technology purposes.

"From an operational perspective, there should be limited impacts," Barnes said, noting that those departments already have HIPAA practices but that the resolution will strengthen and standardize training and policies and put the City Attorney's office in an approval role. Barnes said the ordinance requires the city administrator to review department policies and that the city will revisit the designations every three years and update the list if departments begin providing covered services.

Public callers offered comments; several expressed support for clarity and protections for patient information. Chair Marr moved to send the resolution to the full Board with a positive recommendation; the committee voted 3-0 (Stephanie: aye; Haney: aye; Marr: aye).

Next steps: the resolution will be transmitted to the Board of Supervisors for final action.