Physician Practice

Q&A: Does HIPAA require fax logs?

Physician Practice Insider, February 24, 2015

Q: I was recently hired for a position and learned that the practice has completed handwritten logs for every fax that was sent out since 2003. This document is referred to as the HIPAA fax log and contains the date the fax was sent, to whom it was sent, by whom it was sent, the number of pages, and whether a cover sheet with confidentiality statement was included. I would like to do away with this form since fax machines can generate their own logs. However, if this is a necessary process then I would like to follow official guidelines and update the policies and procedures accordingly. Does the HIPAA Privacy or Security Rule require these logs? If so, what information must we include?

A: Organizations are not required to retain fax logs. However, in accordance with the Accounting of Disclosures requirement, you must be able to respond to a patient's request for a list (account) of disclosures other than for treatment, payment, or operations reasons (with certain other exceptions) going back six years. Most organizations keep the release of information form or similar document in the patient's record with details about the information provided (e.g., information faxed or mailed, send date, staff initials). Some also document this information in the electronic release of information log. I recommend doing both.

Editor’s note: Chris Simons, MS, RHIA, director of health information and privacy officer at Cheshire Medical Center/Dartmouth-Hitchcock in Keene, New Hampshire, originally answered question in the HCPro newsletter, Medical Records Briefing.

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