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FAQ Directory: Long-Term Services and Supports Distinction for Health Plans

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1.15.2025 Privacy Protections for Data Is access to physical and cloud servers in the scope of the Privacy Protections of Data requirement?

Yes. The intent of LTSS 2, Element B in CM-LTSS (HE 2, Element F in HEA; LTSS 1, Element E in HPA) is that organizations have policies and procedures in place for managing access to and use of race/ethnicity and language data that cover all forms of media, devices and data storage.

HP 2025