Corporate Compliance

Tip: When and how to use compound authorizations

Compliance Monitor, April 6, 2011

An authorization to use or disclose protected health information (PHI) may be combined with another document to create a compound authorization only in these situations:

  • An authorization to use or disclose PHI for research may be combined with any other type of written permission for the research study, including the informed consent for participation in the research study
  • An authorization to use or disclose psychotherapy notes may be combined with another authorization only to use or disclose psychotherapy notes
  • An authorization to use or disclose PHI (except psychotherapy notes) may be combined with another authorization except when the covered entity conditions treatment, payment enrollment for the health plan, or eligibility for benefits on one of the authorizations

This week’s tip was adapted from The Privacy Officer’s Handbook. For more information about this book, visit the HCMarketplace.

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