When do both FERPA and HIPAA apply in a training clinic setting?

Both FERPA (Family Educational Rights and Privacy Act) and HIPAA (Health Insurance Portability and Accountability Act) apply in a training clinic setting when the clinic treats clients and conducts covered transactions. This scenario arises because training clinics often operate at the intersection of education and healthcare, where both student records (protected under FERPA) and health information (protected under HIPAA) are managed.

In a training clinic, students often provide services to clients under the supervision of licensed professionals, which means they engage in activities that involve both educational and health care elements. When a training clinic treats clients, it is likely to handle sensitive information that is covered under both laws. For instance, health records created during the treatment process would be subject to HIPAA, while educational records related to the training of the clinic's personnel would be governed by FERPA.

The other scenarios described do not encompass the combined applicability of FERPA and HIPAA as effectively. Providing solely educational services would not require adherence to HIPAA unless health information is involved. Treating only minors could mean either law might apply, but the presence of minors alone doesn't trigger the necessity for both regulations. Finally, handling only physical health records falls strictly under HIPAA, as it does not involve any educational records that