Answer: A joint guidance document from the Department of Education and the Department of Health and Human Services provides good answers to the HIPAA vs. FERPA question. For example, it says:
“Because student health information in education records is protected by FERPA, the HIPAA Privacy Rule excludes such information from its coverage.”
In other words, student education records are protected under FERPA, but exempt from HIPAA, which, in turn, means that the school nurses would not face liability under HIPAA. The student education records information protected under FERPA includes information on immunizations, allergies, medications, and any other information that is part of the student’s education record. Those records are protected by FERPA. FERPA specifically allows transmission of education records without parental consent to a school to which the student is transferring. FERPA also allows the sharing of education records with others in the school who have a legitimate educational reason to see them.
You can find the guidance here: https://www2.ed.gov/policy/gen/guid/fpco/doc/ferpa-hipaa-guidance.pdf