HIPAA Q&A: Fundraising
HIM-HIPAA Insider, September 14, 2012
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Q. As part of its fundraising effort, Hybrid Entity's cancer center wants to send a patient list (demographic information only) to Hybrid's development office, which is not designated as a healthcare component of Hybrid. Is this permissible?
ABC is sharing demographic information only. Does generation of this list by a specialty clinic divulge information about the type of treatment?
A. Covered entities may use or disclose limited PHI to business associates or institutionally related foundations for fundraising.
The development office is considered part of Hybrid Entity and does not have to be specifically designated as a healthcare component. Patient authorization is not required to use PHI for fundraising, but covered entities must tell patients about this use in their Notice of Privacy Practices.
A patient list from the cancer center may reveal general information about a patient's condition, but using only demographic information and dates of service for internal fundraising is acceptable.
This question and answer is printed in the September 2012 edition of the HCPro, Inc. newsletter Briefings on HIPAA.
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