The Board of Education provides coverage to eligible employees under self-funded group health plans. The Board
has established a Medical Plan.
The Board acknowledges that District group health plans are required to comply with the Health Insurance
Portability and Accountability Act (HIPAA) Privacy Rule as amended by Title I of the Information Nondiscrimination
Act (GINA). Certain health information maintained by these group health plans is afforded significant protection by
this Federal law.
The Board hereby appoints the Director of Human Resources to serve as the Privacy Protection Officer of the group
health plans. The Board delegates authority to the Privacy Protection Officer to develop and implement the internal
policies and procedures for the group health plan(s) relating to the use and disclosure of Protected Health
Information, as defined by HIPAA. In the event that the HIPAA Privacy Rule is subsequently amended, the Privacy
Protection Officer is authorized to make necessary amendments to the internal policies and procedures.
The Privacy Protection Officer shall develop administrative procedures necessary to implement this policy.
The Privacy Protection Officer shall report his/her progress to the Board upon request.
Since the Department of Health and Human Services (HHS) has the authority to impose civil monetary penalties
(CMP) for violations of the HIPAA Privacy Rule, the Board agrees to indemnify and hold harmless the Privacy
Protection Officer for any CMP imposed upon him/her in connection with the performance of his/her duties for the
group health plans. Notwithstanding the foregoing language, the Board shall not indemnify the Privacy Protection
Officer in the event the CMP was imposed as the result of intentional misconduct or gross negligence by the
Privacy Protection Officer.
The Board reserves the right to revoke any or all delegations set forth in this policy at any time for any reason.
29 C.F.R. Part 1635
42 U.S.C. 2000ff et seq., The Genetic Information Nondiscrimination Act
Revised: August 29, 2011
Revised: January 24, 2011