What are the limitations of an accounting of disclosures?
There are many limitations in the federal health privacy rule. These limitations make the accounting of disclosures less valuable than it should be. First, health care institutions do not have to account for all disclosures. They don’t have to keep an accounting of disclosures for treatment, payment, or health care operations. They don’t have to keep an accounting of disclosures if you authorized the disclosure. There are other exceptions too. Second, health care institutions do not have to account for uses. A use of information occurs when a record is made available to someone within the institution that maintains the record. A disclosure occurs when a record is shared with someone outside the institution. The accounting requirement only covers some disclosures and no uses. Third, sometimes an accounting that is required to be maintained can nevertheless be withheld from an individual who requests a copy of the accounting. Some disclosures to law enforcement, for example, can be made
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