Health Information Management

Do we need a patient's authorization to disclose PHI to an organ procurement organization?

HIPAA Weekly Advisor, December 6, 2002

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Q: Do we need a patient's authorization to disclose PHI to an organ procurement organization?

A: A covered entity may use or disclose PHI without individual authorization to organ procurement organizations and other entities engaged in the procurement, banking, or transplantation of cadaveric organs, eyes, or tissue for the purpose of donation and transplantation.

In situations in which an individual has not previously indicated whether he or she seeks to donate organs, eyes, or tissues (and therefore already authorized release of PHI for this purpose). Covered entities may initiate contact with organ and tissue donation and transplantation organizations to facilitate transplantation of cadaveric organs, eyes, and tissues.

The HHS commentary clarifies that such organizations are not business associates of the health care facility making the disclosure. This type of disclosure must be included in an accounting of disclosures, unless there is a signed authorization.

Editor's note: Brought to you by attorneys Marty Baxter and Gretchen McBeath at Bricker and Eckler, LLP (http://www.bricker.com) and The Quality Management Consulting Group, Ltd. (http://www.qmcg.com). E-mail: mbaxter@bricker.com or gmcbeath@bricker.com.



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