HIPAA
Education

HIPAA Compliance for Education Companies

Education institutions and EdTech companies may encounter HIPAA obligations when handling student health information — particularly through campus health centers, counseling services, student wellness programs, and disability accommodation offices. The intersection of FERPA and HIPAA in educational settings creates unique compliance challenges, as some student health records fall under FERPA while others are governed by HIPAA, depending on who maintains them and in what capacity.

Why It Matters

  • Campus health centers, counseling services, and student wellness programs that bill insurance are covered entities under HIPAA
  • EdTech platforms for telehealth counseling, student wellness, or campus health must comply with HIPAA when handling student PHI
  • The FERPA-HIPAA intersection means some student health records are FERPA-protected and some are HIPAA-protected, requiring careful classification
  • Mental health data collected through student counseling and wellness platforms carries the highest sensitivity and regulatory scrutiny

Common Challenges

  • Determining whether student health records are governed by FERPA, HIPAA, or both based on who maintains them and the billing relationship
  • Implementing HIPAA controls for campus health services that share infrastructure and staff with FERPA-governed academic operations
  • Securing telehealth and counseling platforms used by students while maintaining the accessibility that student wellness programs require
  • Training campus health staff and counselors on HIPAA requirements that differ from the FERPA training they received for academic records

Key Policies You Will Need

Timeline & Cost

Expected Timeline

6-12 weeks for campus health HIPAA program alongside existing FERPA compliance

Estimated Cost

$15,000-$40,000 for education-specific HIPAA program covering campus health operations

Tips for Education

  1. 1Create a clear decision tree for classifying student health records as FERPA or HIPAA governed based on the maintaining entity and billing relationship
  2. 2Implement separate systems and access controls for campus health center records versus academic records to maintain clear FERPA-HIPAA boundaries
  3. 3Ensure telehealth and virtual counseling platforms used for student services have signed BAAs and meet HIPAA technical safeguards
  4. 4Train student workers and resident advisors who may encounter health information on basic PHI handling and reporting obligations

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