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SESK: Stuff Everyone Should Know · sesk.info/hipaa-workforce-volunteers

Is an unpaid hospital volunteer part of the workforce under HIPAA?

Yes, paid or not.

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  1. Yes, whether paid or not ✔
  2. No, only paid employees
  3. Only after 90 days of service

Why: Workforce means employees, volunteers, trainees and others under the entity's direct control, whether or not they are paid. Every workforce member must be trained on the entity's privacy policies.

Huh, didn't know that: Workforce members are not business associates; their work counts as the covered entity's own.

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I quit my job at the helium factory. I refused to be spoken to in that tone.
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References

Answer: Yes, whether paid or not. Workforce means employees, volunteers, trainees and others under the entity's direct control, whether or not they are paid. Every workforce member must be trained on the entity's privacy policies.

  1. 45 CFR 160.103 (eCFR) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-160/subpart-A/section-160.103
    Workforce means employees, volunteers, trainees, and other persons
    Checked 2026-10-10.
  2. 45 CFR 160.103 (eCFR) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-160/subpart-A/section-160.103
    whether or not they are paid by the covered entity or business associate
    Checked 2026-10-10.
  3. 45 CFR 164.530 (eCFR) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.530
    A covered entity must train all members of its workforce on the policies and procedures with respect to protected health information
    Checked 2026-10-10.

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