The purpose of this Policy is to set forth 91 University’s process for applying sanctions for violations of Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security policies. 91 University has established a comprehensive HIPAA privacy and security program to prevent unauthorized access to protected health information (PHI). This policy sets forth 91's approach to applying consistent sanctions upon completion of investigations.
This policy applies to the workforce members of 91 University’s Healthcare Clinics. 91 University is a hybrid entity. Only the health care component (i.e., the covered functions) of 91 University must comply with this policy. All references in this policy to “91 University” shall be construed to refer only to the health care components of 91 University.
PUNet ID required to review.
Updated April 2025