Chief Compliance and Ethics Officer Health Care

Authorization for Use and Disclosure of PHI

  • 1.  Authorization for Use and Disclosure of PHI

    Posted 03-24-2020 01:02 PM
    ​Hi Everyone!

    I hope you are well and weathering these challenging times.

    I am in search of a new Authorization for Use and Disclosure of PHI. Currently, I have multiple authorizations, one for normal release of records, one for HIV/AIDS records, one for Psychotherapy Notes, etc. I would like to condense some of these to make the paperwork easier for our teams to use. Would any of you be willing to share your authorizations where you have combined some of these into one?

    Thank you, in advance, for any help you might offer.

    ------------------------------
    Gregory Ehardt
    Vice President of Corporate Compliance
    CHRISTUS Health
    ------------------------------
    2020 HCCA Compliance Institute


  • 2.  RE: Authorization for Use and Disclosure of PHI

    Posted 03-24-2020 03:04 PM
    Greg, on our form we have a list of various records (the most common) as well as a box for "psychotherapy notes" and a box for "other".  The patient can check the PN box or they can use the "other" and write what they want.

    ------------------------------
    David Garrison
    Compliance/Privacy Officer
    SEARHC
    Juneau,AK
    ------------------------------

    2020 HCCA Compliance Institute


  • 3.  RE: Authorization for Use and Disclosure of PHI

    Posted 03-24-2020 03:14 PM
    David, Greg and others,
    Do you actually have "psychotherapy notes"? If so, where do you keep them? How often do you get requests for them? I ask because there is a lot of confusion in the mental health world as to what these notes are and are not. To be clear, I am not confused, as i think it is very clear in HIPAA regulations as to what they are.

    ------------------------------
    David Rothery, CHC, AWI-CH
    Compliance & Privacy Officer
    Health & Human Services
    Marin County, CA


    These are my personal opinions and not those of the County of Marin
    ------------------------------

    2020 HCCA Compliance Institute


  • 4.  RE: Authorization for Use and Disclosure of PHI

    Posted 03-24-2020 03:23 PM
    I'm not aware that we have any Psychotherapy Notes.  BH providers say yes, but then when I share the HIPAA definition they all then say "no".

    ------------------------------
    David Garrison
    Compliance/Privacy Officer
    SEARHC
    Juneau,AK
    ------------------------------

    2020 HCCA Compliance Institute


  • 5.  RE: Authorization for Use and Disclosure of PHI

    Posted 03-24-2020 03:26 PM
    Yes, that's usually the case David. I don't think too many patients would know what a HIPAA defined psychotherapy note actually is, let alone understand the "scribblings" of the therapist during a session.

    ------------------------------
    David Rothery, CHC, AWI-CH
    Compliance & Privacy Officer
    Health & Human Services
    Marin County, CA


    These are my personal opinions and not those of the County of Marin
    ------------------------------

    2020 HCCA Compliance Institute


  • 6.  RE: Authorization for Use and Disclosure of PHI

    Posted 03-24-2020 03:41 PM

    You are both right. We have the auth, but I have not heard of someone requesting them. I do this out of an abundance of caution.

     

    Thank you both!

     

    Gregory J. Ehardt, JD, LL.M.

    Vice President

    Compliance and Privacy

    Civil Rights Officer

    CHRISTUS Health

    919 Hidden Ridge

    Irving, TX 75038

     




    2020 HCCA Compliance Institute


  • 7.  RE: Authorization for Use and Disclosure of PHI

    Posted 03-24-2020 04:51 PM
    Dental is easy. Everything is the same. "We don't got no..." well you know.

    ------------------------------
    Carl Russell
    Compliance Analyst, CHPC
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
    ------------------------------

    2020 HCCA Compliance Institute