Health Information Management

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

HIM-HIPAA Insider, May 18, 2015

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

Q: Is it HIPAA compliant to have financial counseling and/or admission representatives in the lobby or waiting area of a hospital if they are in cubicles with or without doors? Specifically, consider that these cubicles may be in an area that cannot be secured after hours, although security cameras are in place and security guards make rounds overnight.
Additionally, would it be a violation of HIPAA to conduct charity interviews and discuss patient billing in such an environment?
A: The HIPAA Privacy Rule requires that covered entities take reasonable steps to protect patient privacy. If admitting or financial counseling procedures must be done in a waiting area or cubicles without doors, consider practical steps you can take to minimize incidental disclosures.
For example, instead of reading a patient's address, date of birth, and insurance information aloud for verification, you could print the information for review. You could also ask the patient to review the information on a computer screen and provide any needed updates.
Staff should be trained to keep their voices low, so others can't easily overhear their conversations. In addition, a private office or conference room should be available if needed for patients who are upset, have hearing disabilities, or require additional privacy.
If these areas cannot be secured after hours, staff should not leave any PHI in their work areas. In such an instance, PHI should be placed in locked files when a staff member leaves his or her work area.
Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS, vice president of health information at the Central Texas Division of Baylor Scott & White Health in Temple, Texas, answered this question for HCPro’s Briefings on HIPAA newsletter. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions.

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