Confidentiality, Privacy and Security

Accounting of Disclosures

  • 1.  Accounting of Disclosures

    Posted 07-07-2020 09:21
    Per the Rule, an Accounting of Disclosures excludes disclosures made for Payment, Treatment, and Operations. Our organization has had only a few Accounting of Disclosures requests.

    Have other organizations included disclosures to registries, for example the Trauma Registry, in their report to the requester/patient?

    Additionally, do you provide the disclosures from a period of six (6) years?

    Thank you in advance for your help.

    ------------------------------
    Marianne Mao
    Privacy Specialist
    Memorial Healthcare System
    ------------------------------


  • 2.  RE: Accounting of Disclosures

    Posted 07-07-2020 09:48
    Marianne,

    I recall reading in several instances (folks can search the Net) that a trauma registry, similar to other registries such as for tumor registries, fall within public health activities.  Therefore, this also means that this falls outside of the types of disclosures which an Accounting of Disclosures may exclude.

    The few times I've seen requests...because they are so rare...it's a good idea to ask if the individual is interested in a particular time period.

    BONUS...as you may have seen in other requests...people learn about their right to request and accounting and often will use it in an attempt to see if someone who works at a hospital may have inappropriately accessed their chart which often even if someone was snooping, this does not in and of itself mean that the "snooper" is going to appear on the report.

    ------------------------------
    Frank Ruelas
    Compliance Professional
    Arizona
    ------------------------------



  • 3.  RE: Accounting of Disclosures

    Posted 07-07-2020 15:48
    Thank you Frank - I just want to clarify your sentence here: "Therefore, this also means that this falls outside of the types of disclosures which an Accounting of Disclosures may exclude."

    Do you mean that the AOD would exclude, and therefore NOT include these disclosures? Or do you mean that it falls outside the disclosures that are excluded, and therefore are INCLUDE these disclosures in the AOD?

    Does your organization exclude these disclosures from the AOD?

    ------------------------------
    Marianne Mao
    Privacy Specialist
    Memorial Healthcare System
    ------------------------------



  • 4.  RE: Accounting of Disclosures

    Posted 07-07-2020 16:39
    Thanks for circling back!  Sorry for not being clear.

    Let me try again.  If a covered entity is disclosing PHI to a trauma registry.  That disclosure would need to be included in an Accounting of Disclosure.

    Hope that helps.  Thanks again.

    ------------------------------
    Frank Ruelas
    Compliance Professional
    Arizona
    ------------------------------



  • 5.  RE: Accounting of Disclosures

    Posted 07-07-2020 20:12

    Thank you for the clarification! 



    ------------------------------
    Marianne Mao
    Privacy Specialist
    Memorial Healthcare System
    ------------------------------