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 09/13/22''' <br />
Revised Date: '''06/06/24'''<br />
Revised Date: ''' ''' <br /><br />
Revised Date: '''06/06/24'''<br />
<big>'''Accounting of Protected Health Information Disclosures Policy'''</big>  
<big>'''Accounting of Protected Health Information Disclosures Policy'''</big>  
== Basis for Policy ==  
== Basis for Policy ==  
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It is the policy of Nebraska Medicine (Nebraska Medical Center, Bellevue Medical Center and UNMCP)/UNMC to comply with the procedures set forth below.
It is the policy of Nebraska Medicine (Nebraska Medical Center, Bellevue Medical Center and UNMCP)/UNMC to comply with the procedures set forth below.
#An individual has a right to receive an accounting of disclosures of PHI made by the ACE during a time period specified up to six (6) years prior to the date of the request, except for disclosures:
#An individual has a right to receive an accounting of disclosures of PHI made by the ACE during a time period specified up to six (6) years prior to the date of the request, except for disclosures:
#*To carry out treatment, payment or health care operations (including permissible disclosures to other providers for their treatment, payment or health care operations);
#*To carry out treatment, payment or health care operations (including permissible disclosures to other providers for their treatment, payment or health care operations).
#*To the individual about his or her own information ;
#*To the individual about his or her own information;
#*Authorized by the individual '''(signed authorization) is this [https://info.unmc.edu/_documents/hippa-docs/_accounting-of-disclosures-form.pdf Request for Accounting of Disclosures of Health Information Form]??''';
#*Authorized by the individual written 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 UNMC Policy No. 6057, [[Use and Disclosure of Protected Health Information]]);
#*As part of a limited data set (see UNMC Policy No. 6057, [[Use and Disclosure of Protected Health Information]]);
#Individuals shall make their requests to the Health Information Management Department (HIM), using the '''is this the most recent form and the correct one to use in place of Attachment 1? If not, I will need a link to Attachment 1 [https://info.unmc.edu/_documents/hippa-docs/_accounting-of-disclosures-form.pdf Request for Accounting of Disclosures of Health Information Form]??''';
#Individuals shall make their requests to the Health Information Management Department (HIM), 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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== Definitions ==
== Definitions ==
===Affiliated Covered Entity (ACE)===
===Affiliated Covered Entity (ACE)===
Legally separate covered entities that are affiliated and designate themselves as a single covered entity for the purpose of HIPAA Compliance. Current ACE members are: The Nebraska Medical Center, UNMC Physicians, UNMC, University Dental Associates, Bellevue Medical Center and Nebraska Pediatric Practice, Inc. d/b/a Children’s Specialty Physicians. ACE membership may change from time to time. The Notice of Privacy Practices lists current ACE members. Access and amendment rights apply to designated record sets throughout the ACE.
Legally separate covered entities that designate themselves as a single covered entity for the purpose of HIPAA Compliance. Current ACE members are: The Nebraska Medical Center, UNMC Physicians, UNMC, University Dental Associates, Bellevue Medical Center and Nebraska Pediatric Practice, Inc. d/b/a Children’s Specialty Physicians. ACE membership may change from time to time. The Notice of Privacy Practices lists current ACE members.  


===Health Care Operations===
===Health Care Operations===
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#General administrative and business functions;
#General administrative and business functions;
#Insurance activities relating to the renewal of a contract of health insurance;
#Insurance activities relating to the renewal of a contract of health insurance;
#Evaluating healthcare provider and plan performance;
#Evaluating health care provider and plan performance;
#Resolution of internal grievances; and
#Resolution of internal grievances; and
#Fundraising.
#Fundraising (see [https://wiki.unmc.edu/index.php?title=Use_and_Disclosure_of_Protected_Health_Information&action=edit#Use.2FDisclosure_of_PHI_for_Marketing Use/Disclosure of PHI for Marketing]).
===Payment===
===Payment===
Activities undertaken by a health care provider or health plan to obtain premiums, to determine or fulfill its responsibility for coverage and provision of benefits under the health plan or to obtain or provide reimbursement for the provision of health care. Some of these types of activities include determinations of eligibility or coverage (including coordination of benefits or the determination of cost sharing amounts), billing, collection activities, claims management, medical necessity determinations, utilization review activities including pre-certification and pre-authorization of services, disclosure to consumer reporting agencies related to collection of premiums or reimbursement and health care data processing related to the above-listed activities.  
Activities undertaken by a health care provider or health plan to obtain premiums, to determine or fulfill its responsibility for coverage and provision of benefits under the health plan or to obtain or provide reimbursement for the provision of health care. Some of these types of activities include determinations of eligibility or coverage (including coordination of benefits or the determination of cost sharing amounts), billing, collection activities, claims management, medical necessity determinations, utilization review activities including pre-certification and pre-authorization of services, disclosure to consumer reporting agencies related to collection of premiums or reimbursement and health care data processing related to the above-listed activities.  
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*an Individual’s genetic tests;  
*an Individual’s genetic tests;  
*the genetic tests of an Individual’s family members; or
*the genetic tests of an Individual’s family members; or
*the manifestation of a disease or disorder in such Individual’s family members (i.e., family medical history); or
*the manifestation of a disease or disorder in such Individual’s family members (i.e., family medical history).
*any request for, or receipt of, genetic services (e.g., genetic test, genetic counseling, genetic education), or participation in clinical research which includes genetic services by the Individual or any family member of the Individual.
PHI excludes:
PHI excludes:
*individually identifiable health information of a person who has been deceased for more than fifty (50) years.
*individually identifiable health information of a person who has been deceased for more than fifty (50) years.
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*[https://www.cdc.gov/phlp/publications/topic/hipaa.html#security-rule HIPAA Security Rule]  
*[https://www.cdc.gov/phlp/publications/topic/hipaa.html#security-rule HIPAA Security Rule]  


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