Depends on whether the programs are both under the covered component of
your organization (if you are considered a hybrid organization), or if
one program has a business associate relationship with the other. If
not, then you will need to look into the purposes of the disclosures and
determine if these will continue to be allowable under HIPAA. If they
are not allowed, then you will need to have individual authorization to
continue to share. A confidentiality agreement does not negate the need
to get this authorization. 

Vicki Hohner
FOX Systems, Inc.
360-970-6856
360-352-4584
Information transmitted is confidential and may be proprietary to FOX
Systems, Inc.  It is intended only for the person or entity to which it
is addressed.   Anyone else is prohibited from disclosing, copying, or
disseminating the contents or attachments.  If you receive this in
error, please notify sender immediately, or us at www.foxsys.com and
delete from your system.
>>> Brian McGrath <[EMAIL PROTECTED]> 03/20/03 07:50 AM >>>
I am unclear as to what the regs mean in regards to an Agency that is
running several different programs under one umbrella. May 2 programs
share
client info without a confidentiality agreement if they are part of the
same
agency?


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