Health Information Management

HIPAA Q&A: You’ve got questions. We’ve got answers!

HIM-HIPAA Insider, June 30, 2014

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Submit your HIPAA questions to Editor Jaclyn Fitzgerald at and we will work with our experts to provide you with the information you need.

Q: I work for an ophthalmology practice that sees many patients from skilled nursing facilities (SNF). The SNFs often send my organization information sheets about the patients that include logistical information along with medications and clinical diagnoses. The SNF requests that the ophthalmologist complete and return paperwork that summarizes the patient's visit. Is copying the patient's visit summary for that day and returning it to the SNF in a sealed envelope acceptable, or does this violate the minimum necessary requirement?
A: This is acceptable. The information is for continuing care. Thus, it falls under HIPAA permissible disclosures for treatment, payment, and healthcare operations. A copy of the office note should meet the minimum necessary standard for information that should be returned to the nursing home.
Editor’s note: Chris Simons, MS, RHIA, director of HIM and privacy officer at Cheshire Medical Center/Dartmouth-Hitchcock in Keene, New Hampshire, answered this question for HCPro’s Medical Records Briefing newsletter.

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