Under HIPAA, patients have the right to request an accounting of their protected health information (PHI) disclosures. The provision allows patients to have control over their personal health data.
There are steps healthcare professionals can follow when providing their patients with an accounting of disclosures.
1. Understand the accounting of disclosures
The first step to effectively provide your patients with an accounting of disclosures is to familiarize yourself with the concept under HIPAA. The accounting of disclosures allows patients to access information about certain non-routine disclosures of their PHI. Routine uses and disclosures for treatment, payment, and healthcare operations are generally not included in the accounting.
Related: What are patient rights under HIPAA?
2. Identify covered entities' obligations
As a covered entity, you must maintain records of certain PHI disclosures. This includes non-routine disclosures such as those made for research, public health reporting, and law enforcement purposes. Establish processes to track and document these disclosures accurately.
3. Determine disclosures covered by accounting
To provide your patients with accurate and relevant information, recognize which disclosures are included in the accounting of disclosures. Focus on non-routine disclosures for purposes other than treatment, payment, and healthcare operations. For instance, disclosures related to :
- Court orders
- Research studies
- Public health reporting
4. Educate your staff
Ensuring compliance with accounting of disclosures requirements involves educating your staff about the process. Provide training to your administrative personnel and medical professionals to handle patient requests for the accounting of disclosures. Emphasize the importance of safeguarding patient privacy and complying with HIPAA regulations.
5. Develop a request process
Creating a standardized process for patients to request their accounting of disclosures streamlines the procedure. Design a simple form that patients can use to submit their requests in writing. The form should include fields for:
- The patient's name
- Contact information
- The desired period for the accounting.
6. Establish a response timeline
To meet HIPAA requirements, set a reasonable timeline for responding to patient requests for the accounting of disclosures. HIPAA regulations generally require covered entities to respond within 30 days of receiving the request. Ensure your team is prepared to adhere to this timeframe and prioritize timely responses.
7. Verify patient identity
Before disclosing any PHI, verify the identity of the patient making the request. Implement security measures to prevent unauthorized access to sensitive information. Verifying patient identity helps protect patient privacy and ensures the information is shared only with authorized individuals.
8. Gather the accounting information
Once a patient request is verified, compile the accounting of disclosures information.
Include relevant details such as:
- Date of disclosure
- The recipient of the PHI
- The purpose of the disclosure
- A brief description of the information disclosed.
9. Share the accounting with the patient
Provide the patient with their accounting of disclosures within the designated timeframe. Use secure communication methods such as HIPAA compliant email to transmit the information. Prioritize patient data security during the transfer process to maintain confidentiality.
10. Address patient concerns
Be prepared to address any questions or concerns from the patient regarding the accounting of disclosures. Clarify the purpose of each disclosure and address any discrepancies or unauthorized disclosures promptly. Being responsive and transparent will help build trust with your patients and demonstrate your commitment to safeguarding their PHI.
11. Document the process
Maintain a record of each patient's request and the subsequent accounting of disclosures provided. This documentation aids in compliance and potential audits. A detailed record of your patient interactions ensures accountability and demonstrates your adherence to HIPAA regulations.
Providing your patients with an accounting of disclosures of their PHI is a legal requirement under HIPAA and builds trust and transparency in your healthcare practice.
Liyanda Tembani
