Hi - I have been approached by the VP of fundraising for our hospice who wishes to approach caregivers of hospice patients who have left positive messages for fundraising purposes. They would be obtaining the information from patient records, and the hospice foundation that does fundraising is a separate entity from hospice and it has been asked if the fundraising VP can access this PHI or would a BAA be needed? I haven't seen this type of requirement for any type of foundation - hospice, hospital or otherwise - but now I am starting to wonder if this truly is needed. If not, is there something I can point to that shows the foundation is not a BAA or at least part of the organization? The LLC is the tricky part.
Thank you for any assistanceLance