HIPAA & Health Information Disclosure Notice

Vista Verde Homes – Medicaid Meals Program Effective Date: [Insert Current Date or "February 2026"]

Vista Verde Homes is a 501(c)(3) nonprofit organization whose sole mission is to serve as a community resource navigator and referral source. We provide free, voluntary assistance by offering education about available public and community resources, conducting basic non-clinical eligibility pre-screening (where required by partners), and facilitating referrals to appropriate third-party programs and services—such as meal delivery options potentially aligned with Medicaid or other public benefits.

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We do not provide healthcare, clinical services, nutritional counseling, case management, benefit enrollment, eligibility determinations, or any form of medical or therapeutic support. Our interactions are informational and connective only.

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1. We Are Not a HIPAA-Covered Entity – And Why This Matters

Vista Verde Homes is not a "Covered Entity" under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), as amended by subsequent rules. HIPAA applies to healthcare providers, health plans, and healthcare clearinghouses that transmit protected health information (PHI) in connection with covered transactions (e.g., billing or claims).

We do not:

• Provide, coordinate, or deliver any healthcare, medical, clinical, diagnostic, or treatment services;

• Transmit health information for purposes of payment, healthcare operations tied to treatment, or standard HIPAA transactions;

• Act as a health plan, insurer, or clearinghouse;

• Enroll individuals in Medicaid, Medicare, managed care, or any public/private insurance programs;

• Make medical necessity determinations, clinical judgments, or benefit eligibility decisions on behalf of any agency or payer.

Because we function exclusively as a non-clinical referral source and resource connector, HIPAA's full requirements—including the obligation to provide a formal Notice of Privacy Practices under 45 CFR § 164.520—do not apply to us. However, we voluntarily adopt strong privacy practices to protect the limited information individuals share with us.

Participation with Vista Verde Homes does not create any provider-patient relationship, fiduciary duty, clinical responsibility, duty of care, or ongoing case management obligation.

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2. No Medical, Clinical, Nutritional, Enrollment, or Decision-Making Services

To be explicit, Vista Verde Homes does not and will not:

• Offer medical advice, diagnosis, treatment, prescriptions, or referrals for clinical care;

• Provide nutritional assessments, therapy, counseling, meal planning, or dietary prescriptions;

• Determine, certify, or influence eligibility for Medicaid, Medicare, SNAP, meal programs, or any other benefits;

• Submit applications, claims, authorizations, or appeals on behalf of individuals;

• Manage cases, coordinate care, or follow up on health outcomes;

• Represent or act as an agent for CMS, any state Medicaid agency, managed care organization, insurer, or government program.

All referrals are informational suggestions only—individuals must independently contact and work directly with the referred organization or agency.

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3. Limited Information Collection – Strictly for Referral Purposes

We intentionally collect only the minimum information needed to identify potential resource matches and make appropriate referrals. We do not request, receive, or maintain medical records, clinical notes, diagnoses, treatment plans, lab results, or any Protected Health Information (PHI) as defined by HIPAA.

Examples of limited, voluntarily provided information may include:

• Self-reported status in public programs (e.g., "Yes, I am enrolled in Medicaid");

• General, non-clinical dietary preferences or restrictions (e.g., "I avoid gluten" or "I need soft foods");

• Responses to partner-required screening questions for eligibility routing;

• Basic contact details and consent to share referral-related information.

Providing any information is entirely voluntary. You may skip any question or withdraw consent at any time without penalty—though this may prevent us from making targeted referrals.

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4. How We Use and Share Information – Minimum Necessary & Referral-Only

Any information shared with us is used exclusively to:

• Educate about resource options;

• Perform basic, non-clinical pre-screening to identify suitable referral pathways;

• Facilitate introductions or referrals (with your express consent where required).

We apply a strict "minimum necessary" standard: only the least amount of information required for the specific referral purpose is shared. Information is never:

• Used for clinical decision-making, diagnosis, treatment, or health assessments;

• Sold, rented, traded, or used for marketing, fundraising unrelated to our core mission, solicitation, research, or commercial purposes;

• Disclosed beyond the specific partner(s) directly involved in the requested resource (and only with your consent when applicable).

Once referred, third-party organizations (e.g., meal providers, government agencies, healthcare entities) handle information independently under their own policies and legal obligations. We have no control over their practices and assume no responsibility for how they manage or use data post-referral.

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5. Privacy Safeguards We Follow (Voluntary Best Practices)

Although not HIPAA-bound, we implement reasonable safeguards consistent with nonprofit standards and general data protection principles:

• Data access restricted to trained staff/volunteers on a strict need-to-know basis;

• Secure digital tools, encryption for transmissions where practical, and password protections;

• Confidentiality agreements and training for all personnel;

• Data minimization and retention limited to the time needed for referral completion;

• Regular privacy practice reviews.

We cannot guarantee absolute security against every risk, but we prioritize reducing exposure through these measures.

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6. Referrals Are Informational Only – No Guarantees or Liability

As a referral source:

• We offer suggestions based on publicly available information and self-reported details;

• We do not guarantee acceptance, availability, approval, quality, timeliness, or outcomes of any referred service;

• We do not supervise, endorse, partner in a legal sense, or share liability with any third-party provider;

• All decisions, services, and communications occur directly between you and the referred entity.

Individuals retain complete autonomy to accept, decline, or pursue any referral—or seek services elsewhere—at any time.

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7. Alignment with Public Goals – But Full Independence

Our work supports broader objectives like food security and access to public resources, consistent with federal/state guidance for community outreach. However, we are fully independent:

• We do not represent or act on behalf of any government agency, payer, or program;

• We do not determine benefits, submit documentation, or receive reimbursement tied to services.

 

8. Records We Maintain (Non-Clinical Only)

For accountability, we may keep internal logs such as:

• Consent records for sharing referral information;

• Basic referral activity summaries;

• Privacy practice documentation.

These are not medical or clinical records and exist solely for program integrity, grant compliance, and internal review.

 

9. Your Rights and Voluntary Participation

Everything is voluntary. You may:

• Ask questions about our practices at any time;

• Decline to provide or withdraw any information;

• Request no further contact.

This notice supports transparency—your trust matters to us.

 

10. Contact for Questions

For inquiries about this notice, our referral process, privacy practices, or data handling: Vista Verde Homes Medicaid Meals Program Salt Lake County, Utah, United States Email: info@medicaidmeals.com

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