We provide no billable services. Under HIPAA are we obligated to make copies of records for inactive clients seen over 8 years ago?
Even if you provide no billable services and do not bill electronically, you may still be considered a “covered entity” for purposes of HIPAA, because “billing” is only one of a number of “electronic transactions” that may cause a provider to be a “covered entity” under HIPAA. For example, other transactions that are included in the list of “standard transactions” are the 270/271 eligibility inquiry and response or the 278 service authorization. Therefore, you need to more fully examine your agency’s activities to ensure that , besides billing, you do not engage in any of the other enumerated transactions that would cause you to meet the definition of a “covered entity” health care provider. If you determine that you are, in fact, a covered entity under HIPAA, then you must maintain documentation of all PHI disclosures for a period of 6 years. In other words, HIPAA does not require covered entities to release a patient’s medical record after 8 years of inactivity. However, the inquiry
Related Questions
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