I would appreciate any opinions on this one.  Please use citations if you have them since that will help me document any decisions we make.

 

Scenario:

Patient A refers their friend Patient B to his/her doctor.

 

Patient B goes to that doctor.

 

The doctor wants to thank Patient A for the referral and sends a note saying “Thank you for referring Patient B to my office” and that is the extent of it…

 

My first take on this is that it is not a disclosure of PHI, which therefore is not affected by HIPAA.  Patient A already has Patient B’s name, otherwise how could there be a referral.  But, I can also see that once Patient B has seen the doctor the connection of Patient B’s name with having seen the doctor becomes PHI.

 

a)       Would this be a disclosure that Patient B should be given the opportunity to agree or object to?  It seems that would cover it without having to do a formal authorization.  This is what I am leaning toward. 

b)       Should a formal authorization be required?  Seems overkill.

c)       Should the “Thank you” be sent without identifying anyone?  This could work though it may not be as effective.

d)       Should the program be dropped?  Again, this seems unnecessary.

 

Any other opinions?  Is there an OCR guideline that addresses something like this?

 

Thanks in advance for any replies.

 

 

Catherine Lohmeier

Implementations Project Lead

OD Professional Team

888.621.5751 x 15

402.423.6509 x 15

 

 

 

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