With the new provisions covering “business associates” you may now fall under the auspices of HIPAA. This recent survey indicated that only 1/3 of 
those affected were aware. BD
Some hospitals and others that will be impacted by changes to the Healt h Insurance Portability and Accountability Act don't know that rule changes are set to go into effect in 2010, a recent survey found.
The Healthcare Information and Management Systems Society conducted a survey of 150 hospital information technology executives and 26 business associate firms. Under HIPAA, business associates are any organizations that handle patient health information for purposes other than treating patients.
The survey found a third of the business associates were unaware that HIPAA privacy and security requirements had been extended to cover their organizations.
amednews: Upcoming HIPAA changes catching some unaware :: Dec. 11, 2009 ... American Medical News