I have always considered this to mean that you did not necessarily need
separate types of forms, but that certain authorizations must be limited
to single purposes.  

However, if only one authorization form is created, it has to be
designed carefully to meet all the different types of situations
applicable to your business.  I suspect that entities will find a
"generic" form will work for most disclosures, but that certain
disclosures, if applicable (like where you are allowed to condition
treatment/enrollment or where, in research, it is combined with other
information) would need a special form because the language will be
different from the general circumstances where you cannot condition
treatment or where it is combined with other types of
permission/information.

lhc


Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045 
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>>> <[EMAIL PROTECTED]> 01/17/03 06:40 AM >>>
I realized that I may be confused over what it means to have a separate 
authorization. The privacy rules clearly state that a separate
authorization 
is needed for psychotherapy disclosures, that you cannot combine an 
authorization for psychotherapy with an authorization for most other 
disclosures. I assumed that meant you actually had to draft a separate
form 
for psychotherapy disclosures but someone recently pointed out to me
that it 
meant you could use the same authorizations for all disclosures, as long
you 
when you used it for disclosures for psychotherapy, it was just used for
that 
purpose

Thoughts?

Also, the rules state that you cannot combine authorizations where the
entity 
can condition treatment upon its signing (like disclosures to a third
party) 
with disclosures that cannot be conditioned. I assumed that you again
had to 
draft separate disclosures forms but am I mistaken?


Jill Rubin, Esq.
(617)388-2404
[EMAIL PROTECTED]


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