HIPAA Q&A: You’ve got questions. We’ve got answers!
HIM-HIPAA Insider, March 24, 2014
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Submit your HIPAA questions to Associate Editor Jaclyn Fitzgerald at jfitzgerald@hcpro.com and we will work with our experts to provide you with the information you need.
Q. If an ambulance that is not affiliated with our organization transports a patient to our facility, can we give them PHI to use for their billing? Do we need the patient's written authorization?
A. One covered entity (CE), such as a hospital, is permitted to share PHI with another CE-in this case, the ambulance service-for treatment, payment, and healthcare operations, as long as both CEs have a relationship with the individual. Such disclosures do not require patient authorization.
In this case, giving the ambulance company PHI for its billing is considered part of its healthcare operations, so it is permissible under HIPAA. Minimum necessary requirements do apply, so be sure to limit the information you provide to the minimum needed.
For example, if the ambulance company only needs patient demographics and insurance information for billing, you should not provide a copy of the patient's medical record.
Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS,vice president of health information at Baylor Scott & White Health in Temple, Texas, answered this question for HCPro's Briefings on HIPAA newsletter.
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