Hi Gavin,
Technically, I would agree with your comments on HIPAA. However, my experience has revealed a concerning phenomenon. Specifically, many of the human service non-profits with which I work have "business associate agreements" with covered entities. For example, an agency that provides respite care for clients discharged from a local hospital among a whole host of other programs not remotely PHI related. What has happened is that the involved lawyers then extrapolate the implications of HIPAA to the entire agency. Undoing that mindset is quite problematic.
Regards,
Dale
U of Michigan
School of Social Work
.