Health Information Management

HIPAA Q&A: You've got questions. We've got answers!

HIM-HIPAA Insider, October 28, 2013

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Submit your HIPAA questions to Associate Editor Jaclyn Fitzgerald at and we will work with our experts to provide you with the information you need.

Q. Do we need to document state-related mandatory reporting in a patient's disclosure accounting? Do we need to account for disclosures made for patient billing?

A. You do not need to account for state-related mandatory reporting for public health, law enforcement (other than to correctional facilities), court orders, and so forth. You do need to retain a disclosure accounting for a minimum of six years.

At this time, disclosures made for billing do not need to be retained. The HIPAA Privacy Rule does not require covered entities to document disclosures made for treatment, payment, and healthcare operations, when specifically authorized by the patient and under a few other minor exceptions.

Disclosures for billing purposes may need to be tracked in the future depending on the language in the accounting of disclosures rule when it is finalized.

Editor’s note: Chris Apgar, CISSP,president of Apgar & Associates, LLP, in Portland, Ore., answered this question for HCPro’s  Briefings on HIPAA newsletter.

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