Which regulatory requirements govern Care Everywhere when sharing PHI?

• A. GDPR only
• B. FERPA only
• C. HIPAA Privacy and Security Rules, breach notification requirements, and applicable state laws; Business Associate Agreements apply
• D. No regulation

Answer: (C)

Regulating PHI sharing in Care Everywhere centers on HIPAA. The Privacy Rule sets how PHI can be used and disclosed, and the Security Rule requires safeguards to protect ePHI—covering administrative, physical, and technical protections like access controls, encryption where appropriate, and audit capabilities. If a breach occurs, the Breach Notification Rule requires timely notification to affected individuals, the Department of Health and Human Services, and sometimes the media, with timelines defined by law. In addition, applicable state laws may add stricter requirements or additional protections beyond HIPAA.

Because Care Everywhere involves a vendor handling PHI on behalf of a covered entity, a Business Associate Agreement is required. The BAA ensures the vendor implements HIPAA-compliant safeguards, defines permissible disclosures, and outlines breach reporting responsibilities.

GDPR would come into play only if EU data subjects are involved, and FERPA applies to student education records rather than general PHI. So the governing framework is HIPAA along with state law considerations and the Business Associate Agreement.