Health Information Management

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

HIM-HIPAA Insider, January 12, 2015

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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 was recently hired for a position at a long-term care facility. Upon getting acclimated, I learned that the facility 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 facility's 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, answered this question for HCPro’s Medical Records Briefing newsletter. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions.

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