Employee Handbook

14.10 Accounting of Disclosures of PHI

14.10.1 Policy Statement

Individuals have the right to receive an accounting of disclosures of protected health information (PHI) made by the Health Plan.

14.10.2 Policy Interpretation and Implementation

Request for an Accounting of Disclosures of PHI

 

 

 

 

 

 

 

An individual or his/her representative may request an accounting of disclosures of his/her PHI made by the Health Plan during a specified time period of up to six (6) years prior to the date of the request of an accounting. Disclosures must be tracked by the Health Plan for purposes of an accounting except the following disclosures:

  • To carry out treatment, payment or healthcare operations (TPO) as permitted under current law;
  • To the individual about his/her own PHI;
  • To persons involved in the individual's care;
  • For national security purposes;
  • Pursuant to the individual's authorization;
  • To federal/health department officials as permitted under current law; and
  • Those disclosures that occurred prior to April 14, 2004 .

 

 

Time Frame of Accounting Reports

Other than the exceptions noted above, the accounting record must include disclosures of PHI that occurred during the six (6) years (or shorter time period as is specified in the request) prior to the date of such request, including disclosures made by or to any of the Health Plan's business associates.

 

 

Content of Accounting of Disclosures Record

 

 

 

 

 

The content of the written accounting of disclosures record must contain, at a minimum, the following information:

  • Date of the disclosure;
  • Name of the entity or individual who received the PHI;
  • The address of the person receiving the

PHI (if known);

  • A brief description of the PHI disclosed; and
  • A brief statement of the purpose of the disclosure that reasonably informs the individual of the basis for the disclosure, or in lieu thereof, a copy of the individual's authorization or the request for the disclosure.

 

 

Multiple Disclosures

If, during the time period for the accounting, multiple disclosures have been made to the same entity or individual for a single purpose, or pursuant to a single authorization, the accounting may provide the information as set forth in paragraph 3 above for the first disclosure, and then summarize the frequency of number of disclosures made during the accounting period and the date of the last disclosure during the accounting period.

 

 

Time Frame for Providing Accounting of Disclosure Data

 

 

 

An individual's request for an accounting of PHI disclosures must be provided to the individual or representative within sixty (60) days of such request. If unable to provide the accounting within the sixty (60) day time frame, a one time thirty (30) day extension may be provided if:

  • The individual is notified in writing of the delay;
  • The notice includes the reason(s) why the delay is necessary; and
  • The notice includes the date by which the accounting will be provided.

 

 

Log

The Health Plan will keep a log of all disclosures, as required by paragraph 1 above, which will include all necessary information.

 

 

Record Retention

A copy of all HIPAA covered information and any revisions shall be maintained for a period of at least six (6) years. Such retention may be in printed or electronic format, or both.

 

 

Privacy Officer

The Privacy Officer is responsible for the development and implementation of the HIPAA policies and procedures. The Privacy Officer is also the contact person for any questions or complaints regarding HIPAA. Questions or concerns about HIPAA rights should be directed to the Privacy Officer during regular business office hours Monday through Friday, except holidays at (651) 696-6280.

 

 

Violations

Violations of this policy will be subject to discipline.