Health Information Technologies and Processes

Accounting of Disclosures and Breach Notifications

  • 1.  Accounting of Disclosures and Breach Notifications

    Posted 09-18-2020 07:36
    Looking to compare and contrast.

    1. Which department receives and processes Accounting of Disclosure requests from individuals?
    2. Does HIM work with other depts/staff such as the Privacy Officer to ensure that the Accounting is complete?
    My reason for asking is that during a recent online conversation, one entity was under the impression (which they now have fixed their process) that if an individual gets a breach notification letter resulting from an impermissible disclosure, then if that same individual requests an Accounting of Disclosure...the impermissible disclosure covered in the breach notification letter is not required to be listed. It looks like a breakdown (and the error in the process I mentioned earlier) resulted in a few incomplete Accounting of Disclosures getting sent out.

    So that is why I'm asking to see how different departments may be involved because I rarely see the breach notifications coming out of the HIM department, but the HIM department may be responding to requests for an Accounting.  Easy to see how these errors an incomplete Accountings can get created.

    Posted: 4:33 AM AZ time

    Frank Ruelas
    Compliance Professional