Health Information Management

Ask the expert: What special safeguards should we put in place when disclosing PHI to offshore computer developers for systems and application design purposes?

HIM-HIPAA Insider, March 13, 2007

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A: The privacy rule requires that you have a BA agreement (BAA) with outside companies to which you will disclose PHI for business purposes. Because the regulations do not distinguish between domestic and offshore companies, you should execute a BAA with any outside vendor to which you will disclose PHI.

However, I would question the need to disclose actual patient information for systems and application design purposes. Do you really need to use actual patient data or could you make up dummy data that would do the trick?

Editor's note: Mary D. Brandt, MBA, RHIA, CHE, CHPS, president of Brandt & Associates, Inc., a healthcare consulting firm in Bellaire, TX answered this question. 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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