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Under the final privacy rule, what information can go on white boards?

HIPAA Weekly Advisor, August 21, 2002

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Q: Under the final privacy rule, are we permitted to post patient information on white boards?

A: Contrary to the rumors, the privacy rule does not prohibit facilities from using white boards to keep track of patient information.

HIPAA doesn't speak specifically about white boards, but the privacy rule affects how we handle all patient PHI. You have to be careful, but you don't want to frustrate the whole purpose, which is to make treatment more efficient and keep track of what's going on.

Ordinarily, white boards are used to track the tests or procedures pending for patients. The three areas where white boards are most common are emergency departments, special care units, and operating rooms. Usually, every patient's information is on one board. In an emergency room, the board might list the patients' names, their physicians, and the tests they're waiting for. Some facilities also use white boards in patients' rooms.

Follow these tips for protecting patients' privacy when using white boards:

1. Choose the location carefully.
White boards are often posted in one corner of the nursing unit. The problem is that sometimes they're in plain view of the public, and there is PHI on them. You can't always put the board behind the nursing station, but you have to be discreet. If you're going to use them, they should be placed where a casual passer-by can't see the information.

The public typically won't be hanging around the operating room, so you don't have to worry about placement as much there.

But the emergency room is usually crowded with patients and their families and friends, so you have to think carefully about the best place to put a board. You want it to be convenient to your staff, so they can see what's going on, but you don't want it to be convenient to the public.

White boards in patient rooms often include the physician's name and information about the patient's treatment. That's acceptable in a private room, but a lot of rooms are not private. You also have visitors coming in.

If you use white boards in semi-private patient rooms, don't keep them in plain view or include a lot of PHI on them.

2. Limit the information posted.
Use patient initials, rather than full names. You can use the first initial and last name or first name and last initial. Keep it to a minimum. You don't really need all those identifiers up there in order for the board to accomplish its purpose.

If white boards are used for anything other than treatment, the minimum necessary rule applies. So you have to think about what really needs to go on the board, particularly if there's a risk of it being seen by people other than those treating the patient. You have to use a little common sense.

But restricting the boards to patient directory information could be useless. Physicians want to look at the board to check a patient's status and see whether he or she is awaiting an x-ray or test results. Directory information wouldn't allow that.

Answered by Jill Callahan Dennis, JD, RHIA, principal of Health Risk Advantage in Parker, Colorado, and adapted from the upcoming September 2002 issue of Briefings on HIPAA.

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