Confidentiality, Privacy and Security

Parent and Child Records

  • 1.  Parent and Child Records

    Posted 07-19-2019 19:18
    We have a request to gather information about food insecurity for adults with hypertension in order to provide support with grant money. However, food insecurity screening is only done in pediatric visits, not adult visits.

    Theoretically, the information could obtained in a roundabout way: pull the positive peds screenings, identify who the parents/guardians are, and then cross-check those patients to see if hypertension is on their problem list.

    Based on the factsheet release by OCR and the summary by AHIMA, my interpretation is that this process is permitted under the definition of "healthcare operations are permitted for care coordination".

    OCR: https://www.hhs.gov/hipaa/for-professionals/faq/3014/uses-and-disclosures-for-care-coordination-and-continuity-of-care/index.html

    AHIMA: https://healthitsecurity.com/news/hhs-ocr-clarifies-when-health-plans-can-share-phi-under-hipaa

    I'm curious to hear other's thoughts. All feedback is appreciated. Thanks!

    ------------------------------
    Sarah Dietz
    Him & Privacy Manager
    ------------------------------


  • 2.  RE: Parent and Child Records

    Posted 07-22-2019 09:13
    Who is making the request for the information?  Before providing any patient information to a third party I would want to be completely sure that the information can be provided without authorization.  More and more patients are questioning who is getting there information and why?   Some are very suspicious of information going to government programs.

    ------------------------------
    Nancy Davis, MS, RHIA, CHPS
    Director of Compliance & Safety
    Door County Medical Center
    ------------------------------



  • 3.  RE: Parent and Child Records

    Posted 07-22-2019 09:19
    Edited by Sarah Dietz 07-22-2019 09:19
    Thank you for asking! The Community Care Team is asking for this information. The intention is to use DHS grant money to fund CSAs for people with hypertension.

    ------------------------------
    Sarah Dietz
    HIM & Privacy Manager
    GHC-SCW
    ------------------------------



  • 4.  RE: Parent and Child Records

    Posted 07-23-2019 08:38
    Is the Community Care Team internal to your organization?  Or external?  If external, I think it might be difficult to share this information without patient consent/awareness.

    ------------------------------
    Nancy Davis, MS, RHIA, CHPS
    Director of Compliance & Safety
    Door County Medical Center
    ------------------------------



  • 5.  RE: Parent and Child Records

    Posted 07-23-2019 16:51
    The Community Care Team is internal in the organization. That's why I'm leaning towards allowing it. However, as you pointed out, I'm still wondering if we will need patient consent / awareness?

    ------------------------------
    Sarah Dietz
    HIM & Privacy Manager
    GHC-SCW
    ------------------------------



  • 6.  RE: Parent and Child Records

    Posted 07-24-2019 09:00
    Well, having it be internal certainly does foster the argument that it is healthcare operations.   Based on that, I don't think you need to obtain authorization.  You may want to make patients aware that you have this program.

    ------------------------------
    Nancy Davis, MS, RHIA, CHPS
    Director of Compliance & Safety
    Door County Medical Center
    ------------------------------



  • 7.  RE: Parent and Child Records

    Posted 07-24-2019 17:14
    Thanks so much, Nancy! I appreciate your time to talk through this with me. Have a great day!

    ------------------------------
    Sarah Dietz
    HIM & Privacy Manager
    GHC-SCW
    ------------------------------



  • 8.  RE: Parent and Child Records

    Posted 07-26-2019 16:27
    A few things to consider:

    How would your process withstand the scrutiny of an audit? I suspect that you would want the screening and the hypertension diagnosis together on the adult patient. How does it look if you pull a report of hypertensive patients who weren't screened? Do you need to screen every adult patient?

    Is there any guidance in the grant award to guide your decisions?

    Does it make sense to change workflow? Our facility asks a lot of demographic/social questions when patients register. We use the data in reporting for multiple grants and in applying for new grants. Most of it is clinically significant as we work to understand and treat the whole person.

    Grants can be a lot of work, but they are also very rewarding because you get a chance to help patients achieve wellness.

    Good luck!







    ------------------------------
    Cody Eynon
    ------------------------------