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Several people on our HIPAA implementation team are hoping others
input might help in resolving our question about
HIPAA's instructions to avoid compound authorizations and how that relate
to the use of multi-agency authorization forms.
The final HIPAA Privacy regulations - 164.508 (b)(3) - prohibit
the use of compound authorizations (i.e., combining with any other document an
authorization for use or disclosure of phi...except for limited and specific
exceptions).
We are a county-operated yet multi-jurisdictional behavioral
health organization that plans, contracts, and directly
provides treatment & prevention services. We are one of several
covered health care components of our County government's hybrid entity.
Much of
the clinical work we do is as part of collaborative
teams with other organizations (i.e., court staff, county social service
staff, coordinating offices that serve as fundors, and other community groups,
agencies & service providers).
In the
past, the local human service organizations that staffed such
efforts agreed to use a multi-agency "Universal" authorization form. This
form includes checkboxes for the various organizations involved, and then all of
the other listed elements of a valid authorization. The clinical staff
point out the obvious benefit that staff and the client need only sign one
form.
The other point of view is that proffered by our MIS vendor and
endorsed by several groups similar to ours in the state is the single
purpose release forms, which allow for only one-on-one exchanges of
information between entities. This option assuries that the system records
the limits of each release individually. Primarily the technical staff
consider the single agent/purpose release form to conform to the spirit of the
regulations...but clinicians believe that they will create an overwhelming
paperwork burden on staff & clients.
I've
found the language of this section confusing, and would be interested in knowing
how others have interpreted this section and resolved the issue of handling
releases of information when working with clients involved with numerous
organizations.
Thanks
in advance for any insights you can offer.
Laura Schmitt,
Business Analyst
Fairfax-Falls Church Community Services Board _______________________________________ This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Thank you. |
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