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Page 36 <br />health information as defined under the HIPAA Privacy Rule and the HIPAA Security Rule <br />-covered entities from this Policy avoids all <br />possible conflicts between the HIPAA Rules and the privacy standards in this Policy. <br />This Policy gives precedence to the HIPAA Rules because: <br />1) The HIPAA Rules are more finely attuned to the requirements of the health care system; <br />2) The HIPAA Rules provide important privacy and security protections for protected health <br />information; and <br />3) Requiring a homeless provider to comply with or reconcile two sets of rules would be an <br />unreasonable burden. <br />another part is covered by HIPAA. A Partner Agency that, because of organizational structure, <br />legal requirement, or other reason, maintains personal information about a client at-risk of or <br />experiencing homelessness that does not fall under this Policy (e.g., the information is subject <br />to the HIPAA Rules) must describe that information in its privacy policy and explain the reason <br />the information is not covered. <br />III.Clarity HMIS Uses and Disclosures <br />A Partner Agency may use or disclose PII collected in Clarity HMIS under the following <br />circumstances: <br />To provide or coordinate services to an individual; <br />For functions related to payment or reimbursement for services; <br />To carry out administrative functions, including but not limited to reporting, legal, audit, <br />personnel, oversight and management functions <br />For creating deidentified PII. <br />Partner Agencies, like other institutions that maintain personal information about individuals, <br />have obligations that may transcend the privacy interests of clients. The following additional <br />uses and disclosures recognize those obligations to use or share personal information by <br />balancing competing interests in a responsible and limited way. <br />another part is covered by HIPAA. A Partner Agency that, because of organizational structure, another part is covered by HIPAA. A Partner Agency that, because of organizational structure, <br />or other reason, maintains personal information about a client ator other reason, maintains personal information about a client at-- <br />ATTY/AGR/2025.134/ CORE SERVICE AGENCY CONTRACT (SMC AND RWC) <br />REV: 06-04-25 VR Page 36 of 48 <br />6.L. - Page 39 of 51 <br />136