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Can the HIPAA Privacy and Security Official Position Be Held by a Third Party?
Thomson Reuters / EBIA 
[Guidance Overview] June 1, 2023 "Although there is language in the preamble to the privacy rule that seems to assume that the privacy official will be an employee of the covered entity, there is no explicit requirement to that effect. And because some covered entities (e.g., most group health plans) will not have employees, the privacy official's duties will have to be performed by a third party (for a group health plan, usually an employee of the plan sponsor)." |
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