And since I wasn't quite quick enough to formulate this question earlier....
Would anyone be able to advise on the following:
What about member or patient information we share with our Business Associates or delegated entities? Do the records containing PHI which we share with these organizations also have to appear on our accounting of disclosures log? I know the disclosures are permitted under TPO but just because they're permitted doesn't mean we don't have to log them -- but this could, in some circumstances, equal an extraordinary amount of work.
Any thoughts or advice?