Q.- We resumed regular office work this week and we are taking the temperature of every employee who comes into the building to work. Is the temperature check information subject to HIPAA?
A.- HIPAA applies to protected health information held by covered entities which are health plans, health care clearinghouses and health care providers. You are taking temperatures in your role as an employer and not in your role as a group health plan sponsor. Therefore, the temperature check results are not subject to HIPAA. The results are, however, personal to your employees and should be kept confidential.