Q: We are scanning remittances containing information about multiple patients into our practice management system. Can we include all of the information on the remittance in each patient's chart?
HIPAA Weekly Advisor, July 30, 2007
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A: There is nothing prohibiting you from including a document (in this case a remittance advice) that contains multiple patient information in a single patient's chart. However, a problem arises when you need to transmit the record to another entity. If this occurs, you need to redact all of the information about other patients from the record before you transmit it to another entity for any reason. Also, if a patient requests a copy of his or her record, you would need to redact the information about the other patients before you make a copy of the patient's medical record for the patient or allow the patient to view his or her record. Although HIPAA doesn't specifically prohibit this practice, the appropriate strategy would be to exclude documents listing multiple patients in a single patient record, because of the risk associated with inappropriate release.
Editor's note: Chris Apgar, president of Portland, OR-based Apgar & Associates, LLC, answered this question. This is not legal advice. Consult your attorney for legal matters.
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