The University of Arizona
Health Care Component Designation
The University of Arizona (UA) has designated itself as a Hybrid Entity in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA). A single legal entity that qualifies as a hybrid entity must designate units as its HIPAA Health Care Components in accordance with 45 C.F.R. 164.103 and 164.105(a)(2)(iii)(D). University Privacy performed an assessment to determine which University of Arizona departments, clinics, and programs meet the definition of a Health Care Component. The following criteria were included in the evaluation:
The extent a component would meet the definition of a covered entity if it were a separate legal entity (e.g., healthcare providers).
The current relationship between the University and Banner Health and the requirements to comply with the Academic Affiliation Agreement, the Organized Health Care Arrangement, and the Business Associate Agreement.
Each components use of Protected Health Information (PHI) and Individually Identifiable Health Information (IIHI) and their associated purposes (e.g., research, education, healthcare).
After consideration University Privacy and the Office of General Counsel have designated the following departments, clinics, and programs as Health Care Components under its hybrid designation:
College of Medicine – Tucson
College of Medicine – Phoenix
College of Nursing
College of Pharmacy
College of Public Health
Campus Health
Speech, Language, and Hearing Clinic
LifeSTEP
AZ ClinCore
Additionally, there are several departments that do not meet the criteria of a Health Care Component that may engage with PHI or IIHI to support the HCC designated programs. While they will not need to comply with each of the HIPAA requirements, they will be assigned to take the annual HIPAA training and may participate in other aspects of the HIPAA compliance program.
The HCC designation is effective as of August 14, 2026.