Health Information Management

OCR answers unresolved questions on PHI disclosure and litigation

HIPAA Weekly Advisor, January 24, 2005

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The Office of Civil Rights (OCR), the HIPAA privacy rule enforcement agent within the Department of Health and Human Services, recently released guidance on nine unresolved questions relating to proper disclosure of PHI during litigation.

The questions cover topics such as

  • whether a covered entity may disclose PHI in response to a subpoena, discovery request, or court order
  • when a covered entity must make an accounting for disclosures of PHI during the course of litigation
  • whether lawyers who are business associates must require others to agree to privacy conditions applicable to lawyers

Go to the FAQ section of the OCR Web site for a complete list of the questions and answers.



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