Brian, HIPAA regulates sharing of information, whether internal to a single legal entity (uses) or external (disclosures) in much the same way. Although there are some differences, It is largely dependent on what the purpose of the sharing is, not whether it is internal or external.
So, first the purpose of the information sharing needs to be identified. The rules then indicate which information use/disclosure are permitted, required, or restricted. If permitted, then whether it is external or internal will drive certain requirements (e.g. do you need a business associtate contract, must you account for the disclosures, etc). In the case you present, if both programs are within the same legal entity (or within the health care component of a hybrid legal entity), and the information sharing is permitted (say under payment provisions) then the programs may use (because it is internal) the information, without the need for a business associate agreement (because they are members of the same workforce). Leah Hole-Curry, JD FOX Systems, Inc. 602.708.1045 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 06:45 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? --- 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 --- 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
