In practice, you often have to comply with both, which is exactly why the overlap trips up so many organizations. When your clinicians act as school officials and the records they create are maintained by the district, those records are generally treated as FERPA education records rather than HIPAA protected health information. However, the same clinical data stored in your own EHR or documentation system typically remains PHI subject to HIPAA. The determining factor is who holds the record and in what capacity, not the type of provider. We help you map data flows and controls so both frameworks are satisfied and your Medicaid documentation stays defensible.