Health Information Management

HIPAA Q&A: Donor review

HIM-HIPAA Insider, May 31, 2010

Q. Is a hospital foundation that reviews the daily census to determine whether any donors have been admitted to the hospital in violation of HIPAA?

A. Many hospitals have struggled with this question as they try to balance patient privacy with the desire to cultivate donors who support the hospital. Some hospitals issue VIP cards to their donors, who are instructed to present their cards upon admission if they would like to receive a visit or flowers from foundation staff members. This allows the foundation to recognize the donor during hospitalization without reviewing census lists containing the names of all hospital patients.

Editor’s note: Mary Brandt, president of Bellaire, TX-based Brandt & Associates, LLC, answered this question. This is not legal advice. Consult your attorney regarding legal matters. Brandt is president of Brandt & Associates, Inc., a healthcare consulting firm in Bellaire, TX. She is a nationally recognized expert on patient privacy, information security, and regulatory compliance, and her publications provided some of the basis for HIPAA’s privacy regulations. She is also the former director of policy and research for the American Health Information Management Association.

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