Maintenance of accounting of disclosures
HIPAA Weekly Advisor, July 19, 2004
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Q: Our organization is still struggling to fully understand when we must maintain an accounting of disclosures of PHI. Do we need to keep an accounting when we disclose PHI to our law firm in order to prepare a response for a government agency?
A: The law firm is your business associate (BA) (and you must have a HIPAA-compliant BA contract with the firm). Disclosures of PHI to your BA to assist you with treatment, payment, or healthcare operations do not require an accounting. But if your BA then rediscloses your PHI to a government agency for other than your organization's treatment, payment, and healthcare operations, accounting will likely be required. For example, if redisclosure is for public health purposes, accounting is required.
Editor's note: This question was answered by Kate Borten, CISSP, CISM, president and founder of The Marblehead Group, Inc., a national security and privacy consulting firm focusing on the healthcare industry.
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