WI DHFS Programs and HIPAA

For the Administrative Simplification aspects of HIPAA, health plans are generally defined as any individual or group plan that provides or pays for health care. Certain publicly funded programs are specifically listed by the federal Department of Health and Human Services in the federal regulations it has issued. Several of these kinds of health plans equate to federal and state human service programs supervised by the Wisconsin Department of Health and Family Services.

Here you will find the Wisconsin programs that DHFS believes are impacted by the Administrative Simplification aspects of HIPAA.

Follow the hyperlinks below to be directed to a particular State of Wisconsin Department of Health and Family Services division or program we believe is impacted by the Administrative Simplification aspects of HIPAA.

Program Name	HIPAA Impact	Link to Program Q&A's.	DHFS Division
Medicaid, WisconCare, SeniorCare, BadgerCare, HIRSP and Wisconsin Chronic Disease Programs	Covered entities as health plans.	WI Medicaid	Division of Health Care Financing HIPAA and WI Medicaid
General Relief Medical	A covered entity as a health plan.		Division of Health Care Financing
DHFS Facilities	A covered entity as a provider.		Division of Long Term Care
CIP, COP-W, Community Integration Program, Brain Injury Waiver	Medicaid home and community based waiver programs are part of Medicaid and therefore a health plan. County waiver agencies that administer them are business associates of DHFS and must comply with HIPAA as health plans. Read the letters to DHHS and the response.		Division of Long Term Care
Community Options Program (COP)	COP meets the exclusions for governmental programs from health plan status. Counties may chose to treat it as a heath plan or not, considering how reasonable it is to separate it's administration from those of the Home and Community Based Waiver programs.		Division of Long Term Care
Family Care	Care Management Organizations (CMO's) are covered entities as heath plans. Resources centers do not appear to be covered entities.		Division of Long Term Care
Partnership/PACE	A covered entity as a health plan. The four local sites will need to comply with HIPAA.		Division of Long Term Care
Wisconsin Well Woman Program	A covered entity as a health plan.		Division of Public Health

View a document listing state wide programs supervised by DHFS we believe are NOT health plans under HIPAA. (PDF, 14 KB)

Last updated: October 24, 2008

Wisconsin Department of Health Services

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