Analyzing a question under the HIPAA Privacy Rule follows a common analytic framework, which requires looking at the definitions and rules set forth in the regulations: (1) Is the entity that is disclosing or using the information a covered entity or business associate? If not, HIPAA does not apply; (2) Is the information PHI? If not, HIPAA does not apply; and (3) Is the use or disclosure required or permitted without individual authorization or prohibited without individual authorization? Using this analytic framework, answer the following questions.

1. The City Gazette Newspaper reports that the reality show star, Chloe Cheetah, has tested positive for COVID-19. Ms. Cheetah claims she did not provide the information to the City Gazette and accuses the newspaper of violating HIPAA. Did the City Gazette violate the HIPAA Privacy Rule?

2. City Clinic is a covered entity and provides COVID-19 testing. Does the HIPAA Privacy Rule require City Clinic to report test results to public health authorities absent individual authorization? Does the Privacy Rule permit such reporting?