To help us continue to monitor and prevent any spread of COVID-19 on campus in the Fall, we are again requiring weekly saliva-based testing for all students, faculty and staff who will be on our Lincoln campuses. Regular testing in the Spring allowed us to maintain a positivity rate of less than 1 percent and to quickly contain any spread of COVID-19 on campus. Tests are available Sunday through Thursday each week and will remain required weekly for those without exemptions, until public health guidance advises that we may be able to pivot to random testing.
If you wish to be tested for COVID-19 on a voluntary basis, either because you have been exposed to another individual with COVID-19, or simply as a precaution (even if you have no current symptoms or high-risk exposure), use the Safer Community app to schedule an appointment. If you don't have a smartphone, you can schedule your test using the COVID-19 testing online portal.
In compliance with LLCHD Directed Health Measures, all students, faculty and staff are currently required to wear face coverings.
On-campus vaccination clinics are available for those wishing to receive a vaccine. See the Vaccination Information page for times and locations.
Campus re-entry testing was required for Fall 2021, at the directive of the Lincoln-Lancaster County Health Department, for ALL students, faculty and staff who will be on our Lincoln campuses.
If you are fully vaccinated against COVID-19, you can submit your vaccination information to the Voluntary COVID-19 Vaccine Registry to receive an exemption from weekly testing. For more information about vaccinations and the registry, visit the Voluntary COVID-19 Vaccine Registry page.
You can also request an exemption for one or more of the following reasons:
- You can provide documentation of a positive COVID-19 test in the prior 90 days, and you have completed your 10 days of isolation. Submit an exemption so your Safer Community app will show an “Access Granted” status until the 90-day exemption expires, upon which you will be required to participate in the testing program. If you test positive through the UNL Saliva Testing Program, the Safer Community app will automatically grant you an exemption after your 10 days of isolation, so no need to request an exemption in that case.
- You can provide documentation of a health-care provider’s note that substantiates a medical reason for an exemption request. You will be able to enter university buildings using the Safer Community app.
We are again using the Safer Community App to allow for access to campus buildings and campus activities. Those who have an approved exemption on file will have a continuous "Access Granted" status on the app until such time as any vaccine boosters may be required or other exemptions expire.
Fall 2021 Checklist
- All students, faculty and staff were required to complete re-entry testing Aug. 15-22
UNLESS you had been infected with COVID in the last 90 days; in that case, members of the university community were asked to file an exemption request
- All students, faculty and staff are required to wear face coverings indoors
- Those who have not submitted vaccination information to the voluntary covid-19 vaccine registry are required to complete weekly testing
- Voluntary testing is available for any member of the campus community
- Anyone who is fully vaccinated and has registered in the Voluntary Vaccination Registry will be exempt from weekly testing (see other exemption categories)
UNL is providing saliva-based diagnostic testing to further protect our campus community.
Frequently Asked Questions
About the Fall Saliva Testing Program
When do I need to complete my first saliva test for the Fall semester?
Campus re-entry testing was required at the outset of Fall 2021, at the directive of the Lincoln-Lancaster County Health Department, for ALL students, faculty and staff who will be on our Lincoln campuses. One round of campus re-entry saliva-based testing was required between August 15 and 22 for ALL students, faculty and staff. Individuals who have approved exemptions from the saliva testing program for Fall 2021 are not required to test.
Wellness attendants are currently checking the Safer Community app to grant access to campus buildings.
What is weekly mitigation testing?Weekly mitigation testing requires members of the campus community to complete a COVID saliva test once per week in order to identify asymptomatic cases, and provide an updated look at the presence of the virus in the campus community on a weekly basis.
Why is mitigation testing important?Mitigation testing is a key component of UNL’s overall strategy to safely offer in-person education this semester. It allows us to identify asymptomatic cases before they spread the virus to others. Based on updated guidance for institutions of higher learning from the Centers for Disease Control and Prevention and from Lincoln-Lancaster County Health Department, it is recommended that universities conduct routine screening testing for COVID-19 among the campus community and that those vaccinated for COVID-19 be exempt from such testing.
How often will I need to test?Individuals participating in mitigation testing will need to complete a saliva test once every 7 days. After you receive each test result, your Safer Community app will reset to calculate for you when your next test result is due (by 11:59 p.m. 7 days after your last received result). If you are not able to complete your test a day before the next result is due, or testing is not offered that day, schedule your test a day early to ensure your Safer Community app shows access granted continuously. Individuals who do not complete their required testing on time will lose building access granted on their Safer Community app. Individuals who have approved exemptions from the saliva testing program are not required to test.
Can I submit positive antigen test results to support an exemption from the saliva-based testing program?Yes, you may submit antigen test results for consideration if you also have an accompanying note from a medical provider that shows you experienced COVID-19 symptoms at the time of the positive test result. If you do not have such documentation, you will not be able to receive an exemption. Learn more: Interim Guidance for Antigen Testing for SARS-CoV-2 from the CDC.
If I’ve taken a COVID-19 test recently, do I still need to participate in the university’s saliva-based testing?Yes. Results from any test taken outside of UNL’s saliva-based testing program cannot be linked to the Safer Community app. Thus, results will not trigger an “access granted” status for campus buildings. If you have taken a COVID-19 test recently with a positive result, you can submit an exemption request for the 90-day category.
Who pays for my saliva testing?All saliva testing is free for students, faculty and staff.
What type of test can I expect?The university is requiring saliva-based polymerase chain reaction (PCR) testing for COVID-19. The saliva samples are collected at testing locations across the university’s campuses.
How do I prepare for getting tested?
- If testing as a precaution, continue to wear a face mask, practice social distancing, wash your hands regularly, limit your interactions with others as much as possible.
- If symptomatic or due to exposure, you should self-quarantine and limit contact with others before your test and during the period you are awaiting your results.
What to do while waiting for your test results
- If testing as a precaution, continue to wear a face mask, practice social distancing, wash your hands regularly, and limit your interactions with others as much as possible. The fewer interactions you have, the less likely you are to contract COVID-19 and bring it home with you.
If symptomatic or due to exposure,
Self-quarantine by staying at home, away from other people, until you get your test results. Let those you live with know that you are self-quarantining. When you get your test results, you will be told if you need to isolate at your home and if so, for how long.
Contact your instructor(s)/supervisor to make sure they know you are self-quarantining and discuss any needs you may have during this time period.
- Check your email. The lab will send your test results within about 72 hours to the email address you provided when registering for the test.
- Answer your phone. If you test positive, the Lincoln-Lancaster County Health Department will need to contact you for contact tracing purposes.
- Next steps if your test is positive. Self-report to email@example.com or text 402-266-6865 to learn about isolation options and support resources.
- Review the FAQ section regarding what to do if you test positive or test negative.
How accurate are these tests?Across the clinical evaluation studies cited in the U.S. Food and Drug Administration (FDA) Emergency Use Authorization (EUA) for the SalivaDirect™ assay, there was over 94% agreement in positive results between the saliva test and nasopharyngeal swab-based PCR testing. There was over 90% agreement in negative results.
Is there need for a follow-up nasal swab test to confirm the saliva test result?No, unlike current COVID-19 antigen tests, the accuracy of saliva-based PCR testing does not warrant follow-up nasal swab testing to confirm the result.
Should I take my scheduled saliva test if I have COVID-19 symptoms?If you become symptomatic, you should schedule COVID-19 testing as soon as possible, either through the UNL saliva-based testing program or at the University Health Center. If you test positive, you must isolate and, after recovery, you will be eligible to request a 90-day exemption from the saliva-based testing program. Exemptions are automatically granted for those who test positive through the saliva-based testing program.
Where is the lab?Processing and analysis of all saliva samples occur at the Veterinary Diagnostic Center on East Campus.
Can I still test if I have uploaded my vaccine card to the registry?Yes, any member of the campus community can choose to schedule a saliva test if they wish.
Who is Required to Participate?
Who is required to be tested?
After the first round of campus re-entry testing for everyone between August 15-22, those who have uploaded their vaccination information to the Registry will be exempt from continued saliva-based testing. Similar to this spring, those who can document a recent case of COVID-19 or have a medical exception to saliva testing will be exempt from all testing, including the re-entry test.
Students, faculty and staff who will be on our Lincoln campuses and who have not uploaded their vaccination information to the Registry will be required to participate in several rounds of weekly tests in order to have access to academic buildings and many other campus spaces. The results from these initial rounds of testing will help us determine our testing posture for the remainder of the semester, in close consultation with LLCHD.
What does required mean?Required means you — without an official exemption — must participate in the saliva testing program. Individuals who fail to participate will be subject to disciplinary measures, including being unable to access campus facilities.
How can my employer require me to divulge my medical information, and prevent my access to buildings based on my medical condition?
The U.S. Department of Education Office for Civil Rights issued guidance in March, 2020 related to COVID-19 stating that institutions that follow the Centers for Disease Control and Prevention recommendations and who work in close consultation with public health authorities, can test members of a campus community in order to control and prevent the spread of COVID-19. The CDC has acknowledged the unique nature of University settings that include frequent movement both among the campus community and the broader community and that a strategy of entry testing combined with regular serial testing might prevent or reduce COVID-19 transmission. See CDC guidance from March 17, 2021, SARS-CoV-2 Screening and Testing for Institutions of Higher Education.
The federal Equal Employment Opportunity Commission has stated in its most recent guidelines that COVID-19 testing by employers that is consistent with CDC recommendations meets the Americans with Disabilities Act business necessity standard for faculty and staff.
The University carefully evaluated its interest in maintaining a safe and healthy campus for all members of the campus community, balanced with the rights of students and employees. An unchecked spread of COVID-19 may expose members of the community to serious health risks and could cause substantial disruption to University operations. Thus, the University has a compelling interest in preventing or controlling community spread. Testing — early and often — is an essential element of any plan to control the spread of COVID-19. The University also considered the manner in which the tests are conducted. The saliva tests are significantly less invasive than other testing methods. Based on these factors, the University has determined that required saliva testing is not only reasonable, but a necessary step to try to prevent the spread of COVID-19 within our campus community.
What if I’m not attending classes in-person?All students are required to participate if they come physically to the Lincoln campuses for any reason, even if other than in-person classes.
I am tested weekly at my off-campus job. Do I need to participate in UNL's saliva-based testing program?Yes. Unless you have an exemption, you are required to participate in our university’s testing program.
I’m a faculty or staff member who needs to come to campus. What should I do?Campus re-entry testing is required as noted above. Faculty and staff can schedule a test at any time to start or renew building access. We recommend testing two to three days in advance of coming to campus to ensure that test results are available to gain access via the Safer Community app.
What if I am an employee working from home?University employees who are not physically coming to the Lincoln campuses are not required to participate in the saliva testing — however they are required to be tested prior to accessing any campus facility. Those employees who come to campus infrequently must be tested within one week of accessing any campus facility, and ideally 2-3 days prior.
Are UNL affiliates, emeriti faculty, or volunteers required to test?UNL affiliates, emeriti faculty, and volunteers who share spaces with UNL employees and students on any of the Lincoln campuses are required to participate in the program. Unit leaders who believe they have affiliates, emeriti faculty, and/or volunteers who should participate based on their work proximity to UNL employees and students should submit the names of those individuals so they may be included with the proper designation in the Safer Community app. UNL affiliates, emeriti faculty, and volunteers who do not participate in the testing program and do not have a building access granted status on their app must be escorted into campus buildings as needed.
Why is there a 90-day testing exemption for individuals who have had the virus?Based on the most current information available to national, state and local health officials, individuals who have had the virus and recovered appear to have immunity for around 90 days after onset of the initial infection. Based on that guideline, any member of the campus community who is within that 90-day immunity window will not be required to take part in the saliva-based testing program. If at any time an individual begins showing symptoms or suspects a reinfection within the exemption period, they are required to get a COVID-19 test. After the 90-day exemption ends, individuals are required to start participation in the testing program.
If I take an antibody test and it says I have COVID-19 antibodies, can I request an exemption from the saliva-based testing program?No, the presence of antibodies based on an antibody test does not qualify individuals for an exemption. According to the CDC, serologic tests should not be used to determine if an individual is immune: “The presence of antibodies may decrease a person’s infectiousness and offer some level of protection from reinfection. However, it remains uncertain to what degree and for how long individuals with antibodies (neutralizing or total) are protected against reinfection with SARS-CoV-2 or what concentration of antibodies may be needed to provide such protection.” (See "Antibody Testing Interim Guidelines" on the CDC website.)
I received a positive test result but I feel fine so I think it’s inaccurate. Can I re-test to double check?No. If you have a positive test result, it is very likely that you have COVID-19 and are asymptomatic. You should isolate immediately to avoid spreading the virus to others. UNL’s saliva test is a real-time, reverse transcription PCR-based assay that allows for qualitative detection of SARS-COV2 RNA (the virus that causes COVID-19) in saliva samples. A positive result indicates the presence of SARS-COV2 RNA in a sample. This assay has been evaluated and compared to the gold-standard CDC assay on nasopharyngeal swabs, where 94.6% of positive samples agreed and 100% of negative samples agreed with testing using the CDC assay.
What are the consequences if I don’t get tested?Participating in the saliva testing program is required and any student or employee who does not follow protocols may be subject to discipline through the Student Code of Conduct or Human Resources policies. Any student, faculty or staff not up-to-date with a negative test result will not be allowed access to campus facilities.
Mobile Application and Access to Campus Facilities
How does the mobile app work?Information on use of the Safer Community app can be found on the Safer Community App page.
What is a wellness attendant?Wellness attendants are students or staff stationed at building entrances and charged with granting or denying access to individuals seeking entry. Students, faculty and staff are required to show Building Access Granted on their Safer Community app Status Card to be admitted.
Where will building access status be checked?Wellness attendants may be posted inside entrances to campus facilities. In those facilities, all other entrances may be locked.
Why does my app sometimes show "Access Denied" when first opened?Depending on the quality of your Internet connection, the Safer Community app may show an "Access Denied" when first opened. Once it has connected, it will retrieve your results and refresh the screen accordingly.
What if there is no one checking access at the door of my building?If there is no wellness attendant on duty at your building, and if you are current on your testing and not supposed to be in isolation or quarantine, please proceed as you normally would. Wellness attendants will not necessarily be at every building every day.
Will entrances to campus buildings be locked unless there is a wellness attendant present?No, campus buildings are not locked down. Buildings still have their regularly scheduled open and close times independent of whether there is a wellness attendant staffing an entrance. If a building will have wellness attendants monitoring entrances, the other doors to that building will be locked to encourage traffic flow through the monitored entrances. Individuals who have N Card access to buildings are asked to use monitored entrances when wellness attendants are in use.
What if waiting in line to verify my building access status makes me late for class?It is your responsibility as a student to allow sufficient time to pass the Wellness Attendant station without being late to class. Especially at the start of the semester, please leave sufficient time to have your entry status reviewed prior to entering your classroom building. To help keep lines short, please have your app or printed status card out and ready.
What if I miss a class because I am denied entrance to a building because of testing program requirements?If you miss a class because your pass does not allow you access to a building, it is your responsibility to contact your instructor as soon as possible to make alternative plans for addressing missed course work and class assignments. It is the responsibility of each student to make sure they are compliant with testing program requirements.
What if I don’t have a smartphone?If you don’t own a smartphone, you can use UNL's COVID-19 Reporting system on a desktop or laptop device and obtain your results online. You can print a pass noting your "building access granted" status to show to wellness attendants. If you don't have access to a printer, we've made two print kiosks available, located at the 17th & R Parking Garage on City Campus and at the East Campus Service Building.
Contracted employees and vendors are not able to participate in the on-campus testing program. How will they gain entry to buildings?Contractors and vendors working in buildings will be granted access so long as they are observing UNL COVID-19 policies and procedures. These individuals are expected to wear identifying uniforms or provide identification and explain the reason for their entry into the building to Wellness Attendants upon request.
Visitors are not able to participate in the on-campus testing program. How will they gain entry to buildings?
Visitors (non-faculty, staff, students) who have business in the building where Wellness Attendants are present will need to be escorted into the building at the Wellness Attendant screening area by the person having business with the visitor.
Prospective students and families should be accompanied by Admissions or Department guides who can show their app with approved building access to Wellness Attendants.
New employees are not able to participate in the on-campus testing program until they receive their NUID and download the Safer Community app. How will they gain entry to buildings?
New employees may work with their unit/hiring manager before their first day of work to complete new hire documents, which begins the process to receive an NUID.
The NUID will enable the employee to download the Safer Community app. While the NUID status is pending during the first few days of employment, a new employee will need to be escorted into the building at the Wellness Attendant screening area by an employee of the unit.
How do you plan to keep my data secure?All data systems involved in the analysis and reporting of your test results, including the mobile application, are designed with the highest standards of encryption and security protocols for maintaining data classified with this level of sensitivity. Your results will be encrypted and securely fed to your mobile application or your portal accessible only with your UNL credentials for the purposes of indicating your clearance to enter campus facilities. See Safer Community Privacy Statement.
Test Scheduling and Collection Sites
Where do I go for testing?Testing is offered at multiple locations on City, East and Nebraska Innovation campuses.
Can I get tested somewhere else?
If you are unable to use the free UNL on-campus COVID-19 testing sites, there are additional testing sites in the Lincoln area. Each site varies and appointments and payment may be required. You are encouraged to contact the testing site to confirm what you will need to do prior to receiving a test.
However, test results from off-campus locations, as well as those from the University Health Center, cannot be uploaded into the Safer Community app, and therefore cannot be used to gain building access at UNL.
Same-day appointments are available at the University Health Center. Contact the University Health Center for details to schedule your appointment on the University Health Center website or call 402-472-5000.
The University Health Center maintains a list of after-hours testing sites in Lincoln.
Can I use any of the UNL testing locations or am I assigned to one?Each time you register for your test, you can sign up to use any of the UNL saliva-based testing locations. Choose whichever one is most convenient for your schedule.
What are the hours for testing?Hours and specific locations are available within the Safer Community app.
I want to schedule my follow-up test but it says the testing locations are closed on the date that I’m trying to schedule.The app only allows scheduling of tests 5 days in advance. Once you get closer to the date for which you’d like to schedule, you should be able to schedule it.
Do I have to do anything to prepare for the test?
Once you have scheduled your appointment, plan to arrive at the testing site 5 minutes prior to your appointment. Have your mobile phone with the Safer Community App PLUS a photo id, such as N card, driver’s license or passport available. If you do not have a smartphone, you will need to arrive at your testing appointment with your ID and be prepared to provide your name and NU ID number.
Because it is a saliva test, on the day of your test, drink plenty of water. Thirty minutes prior to your test, avoid food, chewing gum, lozenges/cough drops, lollipops/suckers, tobacco products, lipstick or color lip products, mouth wash and drinks other than water. Watch this COVID-19 Saliva Testing Video to learn how to prepare for and provide the best sample during your testing appointment.
What do I need to bring with me to the testing site?You are required to bring your phone with the Safer Community app downloaded, as well as a photo identification card (NCard or government issued identification card, such as driver’s license or passport).
How long should I expect to wait in line and provide my sample?You should arrive promptly and anticipate around 5 minutes for on-site registration and to provide a sample. However, please allow at least 15 minutes to include any wait time.
Can I get tested during work hours?Yes. Employees should discuss arrangements for testing with a supervisor to minimize impacts on regular duties.
I work at night on campus. Will I have to come in on my own time to get tested?You may provide your saliva samples during your scheduled working hours.
I scheduled a test and now I need to reschedule. What should I do?You can cancel and reschedule in either your Apple or Android app. Under 'Next Step' in the app it shows scheduled tests and there is a cancel button you can select. Then go into schedule a test and select a new time. In the web system, you can cancel or reschedule in the e-mail confirmation.
What if I miss my scheduled testing appointment?Schedule another appointment. Your building access app will turn to “denied” until a negative test result is received to your Safer Community app.
What should I do if I become symptomatic?If you are symptomatic for COVID-19, contact your healthcare provider or the University Health Center, and get tested right away. Don’t wait until your next weekly test is due. Symptomatic individuals may make an appointment to utilize the saliva testing sites. Testing for individuals who are showing symptoms is also available on campus at the University Health Center. If you test positive using the saliva testing, the Safer Community app will automatically grant you an exemption from testing for 90 days after your 10 day isolation period. If you test positive elsewhere, upload your results through the exemption portal, and you will receive 90 days of exemption following your isolation period.
Can I get tested elsewhere and notify UNL of my results?No. You must schedule and complete a test through UNL’s saliva testing program to gain building access status through the Safer Community app and to be compliant with university policy.
How will I receive results?You will receive your results through your Safer Community App. In addition to scheduling your appointments, Safer Community supports daily building access and notifications of your results. If you don't have a smartphone, you can view your results and printable building access passes at the COVID-19 Test Results page on the COVID-19 Reporting site.
How soon can I expect results?The university-led saliva testing program will release results generally within the day that follows the day you test.
It’s been a full day and I still haven’t received my results.Most individuals will receive their test results in the Safer Community app by the end of the day following the day of their test. Rare exceptions might include when a test sample needs to be re-run by the lab. If you haven’t received your results within the day that follows the day you test, please contact firstname.lastname@example.org.
My saliva test is positive—now what?If your saliva test result is positive, you will receive email communication from UNL’s Public Health Advocacy Team who will offer you support and resources regarding isolation housing and for navigating school and work. The Lincoln-Lancaster County Health Department will then contact you by phone to conduct contact tracing. Please be sure to return phone messages/or emails from LLCHD as quickly as possible. The UNL Public Health Team and LLCHD will keep confidential your identity and health information, with UNL sharing information only as needed with LLCHD to coordinate contact tracing and to notify your identified close contacts of exposure. The university will provide isolation housing at no additional cost to students who need it. Residence hall students should contact Residence Life at 402-472-1717 to arrange for isolation housing. Students who need help finding a place to stay to follow isolation guidance can contact Student Advocacy and Support at 402-472-3204.
How will my results be used?The results will feed into the Safer Community app, which students, faculty and staff can use to gain access to campus facilities, by showing a current negative test result to wellness attendants stationed at doorways. (Members of the UNL community who don't own smartphones can present a Safer Community Status Card.) Results will also be used to trigger contact tracing conducted by the Lincoln-Lancaster County Health Department in coordination with the UNL Public Health Advocacy Team.
How do you plan to keep my results private?All data systems involved in the analysis and reporting of your test results, including the mobile application, are designed with the highest standards of encryption and security protocols for maintaining data classified with this level of sensitivity. Your results will be encrypted and securely fed to your mobile application or your portal accessible only with your UNL credentials for the purposes of indicating your clearance to enter campus facilities. If you are not clear to enter facilities, wellness attendants will only know that you either have not completed a recent test or that you recently tested positive; it will not be clear that you tested positive. Other than feeding your mobile application or secure portal, results are only shared with the UNL Public Health Advocacy Team for the purposes of contact tracing in our UNL community, and with the Nebraska Department of Health and Human Services (DHHS) and Lincoln-Lancaster County Health Department (LLCHD). All COVID-19 test results from all entities that conduct testing are required to be shared with DHHS and LLCHD during the COVID-19 pandemic. As of the week of March 29, 2021, this sharing with DHHS also affords UNL participation in the DHHS SARS-CoV-2 variant detection program conducted through the Nebraska Public Health Laboratory. See Safer Community Privacy Statement.
How long will saliva sample materials be kept?
As of the week of March 29, 2021, saliva samples determined to be positive for SARS-CoV-2 by the UNL Saliva Testing program will be shared with the Nebraska Public Health Laboratory for possible SARS-CoV-2 variant testing. When the amount of virus present in a sample is sufficient for variant testing, such testing will be conducted.
Given that multiple variants of SARS-CoV-2 have been identified globally and in the United States, the Nebraska Department of Health and Human Services (DHHS) has initiated a program for detection of and surveillance for these variants in Nebraska. As part of this program, DHHS requested that UNL provide saliva samples positive for SARS-CoV-2 to the Nebraska Public Health Laboratory for whole virus genome sequencing, the only laboratory method available to identify if any variants are present in the SARS-CoV-2 RNA genome from a positive sample. Participation in this program will readily allow for detection of any variant virus sequences, and in turn, thorough case investigations and contact tracing efforts to further mitigate any spread of COVID-19. Individuals whose samples are positive for a variant may be notified by their local county health department, in most cases Lincoln-Lancaster County Health Department (LLCHD).
All saliva samples determined to be negative for SARS-CoV-2 by the UNL Saliva Testing program have been and will continue to be disposed of after three days, following established bio safety practices.
Why doesn’t HIPAA apply to this testing and the use of the results?
HIPAA only applies to certain entities, known as covered entities. Covered entities include health plans, health care clearinghouses and health care providers that engage in certain electronic transactions. Organizations such as schools and universities have some components of their organization covered by HIPAA and other components that are not. It is very common that not all components of universities that handle identifiable information are covered by HIPAA. This testing is being conducted in a component of the University that does not qualify as a covered entity under HIPAA.
A more detailed explanation is offered by the U.S. Department of Health and Human Services (a hybrid entity, such as a university, has the option to exclude a research laboratory that functions as a health care provider but does not engage in electronic transactions).