Psychotherapy
notes are defined very specifically in the regulations including that
the records "are separated from the rest of the individual's medical
record."
Does the
definition imply that a mental health provider who does not keep the
records separate -- not have HIPAA psychotherapy notes? If so, can the
provider release the records under a general HIPAA authorization and not be
required to obtain a separate authorization for release of what may be
classified as "psychotherapy notes" had such records been kept separate and
apart from the other medical records.
Basically was
the definition designed to allow two ways to handle such records. It is my
understanding from discussion with some mental health care providers that they
like to keep some records separate and from others that they put all the records
into the full medical record.
Thoughts. bob coffield
******************************************************
Robert L. Coffield
Flaherty, Sensabaugh & Bonasso,
PLLC
200 Capitol Street (P.O. Box 3843)
Charleston, WV 25338-3843
(304) 347-3791 Fax: (304) 345-0260
Work Email: [EMAIL PROTECTED]
*******************************************************
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