Health Information Management

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

HIM-HIPAA Insider, December 7, 2015

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

Q: We are a family practice clinic with a pharmacy located within our building, which many of our patients use. Is it a HIPAA violation to allow the pharmacy access to our EHR to view charts if they have any questions regarding a prescription?

A: Allowing the pharmacy to have unlimited access to your EHR could be considered a violation of the HIPAA Privacy Rule—the pharmacy does not need access to all patient records because not all patients seen at the clinic will use the pharmacy. You can enter into an organized healthcare arrangement (OHCA) with the pharmacy, which would permit allowing the pharmacy access to your EHR. Per HIPAA, an OHCA means, among other things, “… A clinically integrated care setting in which individuals typically receive health care from more than one health care provider …” (45 CFR §160.103).

Editor’s note: Chris Apgar, CISSP, president of Apgar & Associates, LLC, in Portland, Oregon, answered this question for HCPro’s Briefings on HIPAA newsletter. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions.

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