Does my organization need to document every time a chart is accessed in order to comply with the “Accounting of Disclosures” requirement under the HIPAA Privacy Rule?
No. The Accounting of Disclosures requirement is intended to inform patients about outside entities to which their information is disclosed. Only disclosures, not uses, of PHI must be accounted for. To make the requirement simpler, only disclosures made for purposes other than treatment, payment or health care operations must be documented. The Proposed Changes to the Privacy Rule (released on March 27, 2002) states that only disclosures (made for purposes other than treatment, payment or health care operations) made without a written authorization from the patient must be included in the Accounting of Disclosures. Keep posted to the NM CHILI Website for the latest news on the status of the Proposed Changes to the Privacy Rule. Q: What is the difference between a consent and an authorization? Do I have to get both each time I see the patient? A: Consents are written permission from patients to use and/or disclose their PHI for purposes of treatment, payment and health care operations.
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