Hello,
I have a question with regard to lookup of patient information for the HIPAA
named transaction sets.
We utilize a unique identifier for each subscriber (patient) within our
health care benefit programs.  Thisunique identifier is available on the
member id card along with the subscriber (patient) name.  However, we still
continue to receive claims with member ID's for the mother or father of
children, or spouse's ID number for the husband or wife.  As a result, we
are concerned that we might not be in compliance with the privacy regs with
regard to protected health care information, for our beneficiaries, when
matching the demographic data received to our internal files.

1. If we receive any of the named transactions that require identification
of a patient for health care services,and we utilize an incorrect member ID
that is sent to us, and  we provide a response, that includes protected
health care information, utilizing that information to create our response,
are we violating the Privacy Regulation?

Thank you

Cindy Anaya
Health Administration Center
Denver, CO 80206
303-331-7668

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