John,
The regulations give you some leeway to decide what is treatment, payment
or healthcare operations within your environment. �You might choose to
treat the situations you describe as treatment, payment or healthcare
operations in order to avoid having to obtain an authorization. �If you do,
however, you must obtain an informed consent for the use and disclosure of
protected health information, unless you think you can find away to avoid
the disclosure of PHI in those situations. �It must be disclosed to the
patient that your definition of treatment, payment and healthcare
operations for which PHI will be used and disclosed will include situations
such as those described in your example. �You should consider how best to
make the disclosure in your consent form and notice of privacy policies and
procedures.
Peter
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Peter B. Goldstein
Cap Gemini Ernst & Young, US LLC
4610 South Ulster Street, Suite 600
Denver, Colorado �80237-4323
(303) 796-4148 (Direct)
(413) 740-0512 (Facsimile)
cap comm: 657 4653
[EMAIL PROTECTED]
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