I hate to weigh in here one more time, but my understanding what that we have to 
provide the pt/client an accounting of all disclosures that were not specifically 
covered by an authorization (initially, it was interpreted that those had to be logged 
and tracked also, but that was amended in the final regs, since the argument was made 
that the pt would have knowledge of disclosures s/he had authorized in writing).  I 
know another gentleman on this thread last week indicated that he planned to track 
those also, just to keep the disclosure log complete and to simplify the procedures 
for HIM staff; however, I do believe that authorized disclosures are not required to 
be tracked.

So, our disclosure log must contain a record of all disclosures not covered by a 
written authorization and those that are not a part of treatment, payment and 
healthcare operations.  Regardless of everything we list in the NPP (and it should 
list all these as possibilities), we have to track these and record them, providing 
them for a pt when requested.

Have I confused different parts of the regs in this interpretation?

Teri Baskett, CISO
LifeSpring Mental Health Services

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