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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.

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Updated April 2025