Development of a Health Insurance Portability and Accountability Compliance Plan

The Center for Urban Community Services (CUCS) provides supportive housing and social services, including job-training and placement, technical assistance, and case management, as well as on-site health assessment, psychiatric services, and substance abuse counseling to more than 14,000 homeless mentally ill people in New York City. The Capstone team was initially asked to assist CUCS with the development of a Health Insurance Portability and Accountability Act (HIPAA) compliance plan, requiring a complete organizational assessment and gap analysis. During the process, the State Office of Mental Health awarded CUCS the opportunity to launch a new initiative—the Assertive Case Management Transition (ACT) program. The Capstone team was then asked to define a hybrid entity, develop a modified HIPAA compliance plan based on this definition, assist with elucidating the pre-emption analysis, and research the State of New York’s substance abuse laws.