Im still confused about routine versus nonroutine disclosures. Do I need an authorization for any nonroutine disclosures?
For each nonroutine disclosure outside of TPO, you need a separate authorization. For a routine disclosure outside of TPO, you need one authorization form that states how long the authorization period is valid. Q: At the end of the year, patients call my pharmacy to request the entire year’s record for income tax purposes. What if the wife calls and requests her husbands information? Will I need to get his authorization first? A: An individual has a right to request his or her own information. Use your professional judgment if someones spouse calls. To play it safe, call the husband and ask him if you can release the information. The privacy rule gives you requirements to follow, but it does not give specifics on how you have to get there. You do not have to implement an impossible administrative task to meet those requirements. Use reasonable, professional judgment. Be creative.
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