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


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.
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