Health Information Management

Can we combine patient authorizations?

HIPAA Weekly Advisor, August 1, 2003

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Q: Can we combine patient authorizations?

A: For the most part, the privacy rule does not permit covered entities to combine an authorization form with any other document, including any other written legal permission. Any such combined authorization would be impermissible and defective. The regulations specifically clarify that an authorization cannot be combined with a notice of privacy practices.

The following three exceptions apply to the no-combination requirement:

  • An authorization for the use or disclosure of PHI created for a research study may be combined with any other type of written permission for the same research study, including another authorization for the use or disclosure of PHI for the study or consent to participate.

  • Authorizations for the use or disclosure of psychotherapy notes may only be combined with another authorization for a use or disclosure of psychotherapy notes

  • Authorizations for the use or disclosure of PHI other than psychotherapy notes may be combined, provided that the covered entity has not conditioned the provision of treatment, payment, enrollment, or eligibility on obtaining the authorization

    Editor's note: Brought to you by attorneys Marty Baxter and Gretchen McBeath at Bricker and Eckler, LLP and The Quality Management Consulting Group, Ltd.. E-mail: mbaxter@bricker.com or gmcbeath@bricker.com



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