Another clearinghouse question 164.506 (c)(4) states that (paraphrased):
'A covered entity may disclose protected health information to another covered entity for health care operations of the entity that receives the information, if both covered entities has or had a relationship with the individual who is the subject of the protected health information being requested, the protected health information pertains to such relationship, and the disclosure is for quality related healthcare operations or for the purpose of healthcare fraud and abuse detection or compliance.' My question is as follows: For this purpose, would a health care clearinghouse be considered to have a "relationship" with the individual who is the subject of the protected health information? For instance, in developing policies and procedures for a clearinghouse, would one interpret this provision to permit the clearinghouse to disclose information it has on an individual to other covered entities (who have a relationship with the individual) for the reasons listed? I ask this question for the purpose of policy development. Its obvious to me that the clearinghouse would be permitted to exchange information with the entity from which it originally received the information, but what about other covered entities? (Covered Provider A gives the information to the clearinghouse; if Covered Provider B or Insurance C has a relationship with the individual, would the clearinghouse disclose the individual's information to Covered Provider B or Insurance C for the reasons listed in this reference?) Is this even a concern, or a possibility that this situation would arise? Thanks, Rachel M. [EMAIL PROTECTED] IMPORTANT NOTICE: This e-mail, including attachments, may be confidential or privileged communication intended for the exclusive use of the person or entity to which it is addressed. If the reader of this e-mail is not the intended recipient, the reader is hereby notified that any dissemination, distribution or copying of this e-mail is strictly prohibited. If you think that you have received this e-mail in error, please advise the sender by reply e-mail of the error and then delete this e-mail immediately. --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
