| 8. |
Track any disclosure of PHI: In general, when PHI is disclosed without the involved individual’s written authorization and is not disclosed in order to carry out treatment, payment, or healthcare operations, you must keep a written record of the disclosure and its basis. This does not apply to disclosures to the individual whose PHI is involved or to that individual’s personal representative, disclosures to persons involved in caring for the individual or paying for the individual’s healthcare, or disclosures for disaster relief, for purposes of inclusion in heath care facilities directories, as part of a limited data set, for purposes of national security and intelligence operations, to correctional and law enforcement personnel in certain circumstances where the individual is in custody of such officials, or that occur as an incidental by-product of some other disclosure that is specifically permitted under the Privacy Rule. This record of disclosures should be filed in the patient’s chart since the patient is entitled to annual accounting of disclosures. We have provided you with a form to be signed by the patient requesting such an accounting. |
| 9. |
Re-evaluate all office policies and procedures annually to ensure they comply with HIPAA regulations. You should file a statement in your HIPAA binder each year noting that forms and policies were reviewed for HIPAA compliance and amended as necessary or not amended because none was found to be needed. |
| 10. |
Keep a record of patient requests: Patients have a variety of rights which have been described elsewhere in this document. You should keep a record of patient rights request and their disposition in the patient’s chart. |
| 11. |
Ensure that financial information about each patient is maintained in a separate password protected file. |
| 12. |
Develop and implement a written policy as to how and under what circumstances you will disclose PHI unrelated to TPO. For example, if you do pre-employment examinations, you need a policy describing how you will deal with the PHI in order to protect the patient’s privacy. In the same way, an insurance company request for PHI on which to base coverage decisions requires that you have a policy on how you will disclose such PHI. Except where the disclosure is of a type specifically permitted or required under the Privacy Rule, it will require patients’ signatures on authorization forms meeting the requirements of the Rule.
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