HIPAA

Soliciting Plasma Donors on Behalf of Providers

  • 1.  Soliciting Plasma Donors on Behalf of Providers

    Posted 05-18-2020 03:33 PM
    Edited by Greg Nainani 05-18-2020 07:45 PM
    Hello, forum members!  Would you please share your insights on a HIPPA/BAA question?  First, the brief background:

    Background
    The FDA allows most physicians to access experimental plasma therapy for patients with serious or immediately life-threatening Covid-19 infections.  However, a bottleneck for qualified patients to receive the plasma is the supply of plasma.

    Basically, a physician would need to engage in time-consuming outreach to his or her recovered and qualified COVID-19 patients to ask them if they are ready, willing, and able to donate plasma out of the goodness of their hearts.

    The Question
    If a third-party wanted to take that outreach task off the provider's shoulders, would HIPPA's TPO or Public Interest and Benefit Activities exception (along with a proper BAA) allow a provider to share relevant PHI with a third-party to solicit plasma donors on the provider's behalf?  If not, what would a provider need in order to outsource that task in a compliant manner?

    Thank you!

    Greg


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    Greg Nainani
    Chief Strategy Officer
    Opal 8, LLC
    North Las Vegas,NV
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