Health Information Management

HIPAA Q&A: Donor information in hands of BA

HIPAA Weekly Advisor, May 24, 2010

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Q. I don’t have any business associates (BAs) that have or need access to health information. However, some of my BAs have access to sensitive donor information. Some donor files include a note stating that the individual has been a patient, sometimes indicating the date of admission, sometimes not. The note includes no other details about the patient’s condition or treatment. Do HIPAA rules apply?

A. If your donor database includes names and addresses of individuals designated as “patients,” this information is considered PHI. BAs who have access to your donor database should sign BA agreements to protect this PHI.

Editor’s note: Mary Brandt, president of Bellaire, TX-based Brandt & Associates, LLC, answered this question. This is not legal advice. Consult your attorney regarding legal matters. Brandt is president of Brandt & Associates, Inc., a healthcare consulting firm in Bellaire, TX. She is a nationally recognized expert on patient privacy, information security, and regulatory compliance, and her publications provided some of the basis for HIPAA’s privacy regulations. She is also the former director of policy and research for the American Health Information Management Association.
 



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