Accounting of PHI Disclosures: Difference between revisions

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Policy No.: '''6061'''<br />
Policy No.: '''6061'''<br />
Effective Date: '''03/17/03'''<br />
Effective Date: '''03/17/03'''<br />
Revised Date: '''DRAFT''' <br />
Revised Date: '''DRAFT 04/13/22''' <br />
Revised Date: <br /> <br />
Revised Date: <br /> <br />
<big>'''Accounting of Protected Health Information Disclosures Policy'''</big>  
<big>'''Accounting of Protected Health Information Disclosures Policy'''</big>  
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#*To the individual about his or her own information
#*To the individual about his or her own information
#*Authorized by the individual (signed authorization)
#*Authorized by the individual (signed authorization)
#*For the facility directory or to persons involved in the individual's care, or other notification purposes permitted under law;
#*For the facility directory or to persons involved in the individual's care, or other notification purposes permitted under law
#*For national security or intelligence purposes;
#*For national security or intelligence purposes
#*To correctional institutions or other law enforcement officials who have custody of an individual as permitted under law.
#*To correctional institutions or other law enforcement officials who have custody of an individual as permitted under law
#*As part of a limited data set (see Use & Disclosure of PHI policy)
#*As part of a limited data set (see Use & Disclosure of PHI policy)
#Individuals shall make their requests to the Health Information Management Department, using the [Request for Accounting of Disclosures of Protected Health Information Form].
#Individuals shall make their requests to the Health Information Management Department, using the [https://info.unmc.edu/_documents/hippa-docs/_accounting-of-disclosures-form.pdf Request for Accounting of Disclosures of Health Information Form]
#Content Requirements. The accounting for each disclosure must include:
#Content Requirements. The accounting for each disclosure must include:
#*Date of disclosure;
#*Date of disclosure;
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#:*An IRB waiver;
#:*An IRB waiver;
#:*decedent PHI; or
#:*decedent PHI; or
#:*use of PHI preparatory to research (if over 50 records reviewed, only need to provide description of protocol, purpose of research, description of type of PHI disclosed, time period disclosure occurred, name address, etc. etc.)
#:*use of PHI preparatory to research (if over 50 records reviewed, only need to provide description of protocol, purpose of research, description of type of PHI disclosed, time period disclosure occurred, name address, etc. etc.).
#Department Responsibilities. Health Information Management (HIM) is the designated department for release of patient information. In limited circumstances other areas may release minimal information for such purposes as pre-insurance certification, urgent care, provider communication, releasing test results to the patient, or as otherwise expressly permitted by this or another UNMC policy. All other requests shall be forwarded to the Health Information Management Department for processing. All departments making permitted disclosures of patient information shall document the disclosures in a manner approved by HIM. Departments that maintain health information systems shall alert HIM of the system. When such departments disclose PHI subject to the accounting requirement, department staff shall complete Quick Disclosure tracking documentation in One Chart or establish other record keeping systems for other health information systems and inform HIM of those record keeping systems. A record of such disclosures must be maintained for six years from the date of the disclosure. Departments shall respond to the Health Information Management Department requests for information in response to individual accounting requests within 10 days.
#Department Responsibilities. Health Information Management (HIM) is the designated department for release of patient information. In limited circumstances other areas may release minimal information for such purposes as pre-insurance certification, urgent care, provider communication, releasing test results to the patient, or as otherwise expressly permitted by this or another UNMC policy. All other requests shall be forwarded to the Health Information Management Department for processing. All departments making permitted disclosures of patient information shall document the disclosures in a manner approved by HIM. Departments that maintain health information systems shall alert HIM of the system. When such departments disclose PHI subject to the accounting requirement, department staff shall complete Quick Disclosure tracking documentation in One Chart or establish other record keeping systems for other health information systems and inform HIM of those record keeping systems. A record of such disclosures must be maintained for six years from the date of the disclosure. Departments shall respond to the Health Information Management Department requests for information in response to individual accounting requests within 10 days.
#Provision of Accounting. The Health Information Management Department in coordination with the Privacy Officer shall respond to accounting requests no later than sixty (60) days after receipt. The response time may be extended by no more than thirty (30) additional days, provided that within the first sixty (60) days, the individual is given a written statement of the reasons for the delay and the date by which the accounting will be provided.
#Provision of Accounting. The Health Information Management Department in coordination with the Privacy Officer shall respond to accounting requests no later than sixty (60) days after receipt. The response time may be extended by no more than thirty (30) additional days, provided that within the first sixty (60) days, the individual is given a written statement of the reasons for the delay and the date by which the accounting will be provided.
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#Suspension of the Right to Accounting. Upon request by a health oversight agency or a law enforcement official, a patient/legal guardian's right to an accounting of disclosures to a health oversight agency or law enforcement official may be suspended for the time period specified by the official if the official asserts that the provision of the accounting would be reasonably likely to impede the activities of the official.
#Suspension of the Right to Accounting. Upon request by a health oversight agency or a law enforcement official, a patient/legal guardian's right to an accounting of disclosures to a health oversight agency or law enforcement official may be suspended for the time period specified by the official if the official asserts that the provision of the accounting would be reasonably likely to impede the activities of the official.
===Additional Information===
===Additional Information===
*[mailto:debrbishop@nebraskamed.com Privacy Officer], at 402-559-4705
*[mailto:debrbishop@nebraskamed.com Privacy Officer], at 402-559-5136
*[mailto:mailto:Privacy@NebraskaMed.com Privacy Office]
*[mailto:mailto:Privacy@NebraskaMed.com Privacy Office]
*[Request for Accounting of Disclosures of Protected Health Information Form] - UNDER CONSTRUCTION
*[https://info.unmc.edu/_documents/hippa-docs/_accounting-of-disclosures-form.pdf Request for Accounting of Disclosures of Health Information Form]


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