Privacy Officer's Roundtable

Hi all, wondering what is needed for this scenario:  Provider use to work at CE1, but now works at CE2.  Provider is being asked to testify on behalf of patient they saw when working at CE1.  Provider is willing to testify and patient is willing to give authorization to provider.   Since provider is working at CE2, does CE2 get the authorization?  Does CE1 get it?  Does provider send it to CE1 and get "ok'd" to disclose their PHI?

Thanks

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David Garrison CHC,CHPC
Compliance/Privacy Officer
SEARHC
Juneau,AK
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​I would think the authorization would be for CE1, and provider should let C2 know what is happening.

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Ann Dunham
MBA, SPHR, CHC, CHRC
Compliance Officer
Hannibal Regional Healthcare System
Hannibal, MO
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Original Message:
Sent: 10-24-2018 04:27 PM
From: David Garrison
Subject: Disclosing PHI or previous CE

Hi all, wondering what is needed for this scenario:  Provider use to work at CE1, but now works at CE2.  Provider is being asked to testify on behalf of patient they saw when working at CE1.  Provider is willing to testify and patient is willing to give authorization to provider.   Since provider is working at CE2, does CE2 get the authorization?  Does CE1 get it?  Does provider send it to CE1 and get "ok'd" to disclose their PHI?

Thanks

------------------------------
David Garrison CHC,CHPC
Compliance/Privacy Officer
SEARHC
Juneau,AK
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​David:
My question is: "What is CE2's involvement in this matter?"

If they now hold the patient record, then CE2 should get the authorization. However, if CE1 holds the record, then the authorization should go to the physician who used to work at CE1 AND a separate authorization (for access to the record) should go to CE1.

Just my two cents...

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Dr. Randy Lewis, LMFT, CHPC
HIPAA Privacy Officer
Orange County Government
Orlando, FL
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Original Message:
Sent: 10-24-2018 04:27 PM
From: David Garrison
Subject: Disclosing PHI or previous CE

Hi all, wondering what is needed for this scenario:  Provider use to work at CE1, but now works at CE2.  Provider is being asked to testify on behalf of patient they saw when working at CE1.  Provider is willing to testify and patient is willing to give authorization to provider.   Since provider is working at CE2, does CE2 get the authorization?  Does CE1 get it?  Does provider send it to CE1 and get "ok'd" to disclose their PHI?

Thanks

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

Randy, the provider now works at CE2.  The patient is a patient of CE1 and saw the provider while they worked at CE1.  CE2 has no PHI belonging to the patient, other than what is in the "head" of the provider.

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David Garrison CHC,CHPC
Compliance/Privacy Officer
SEARHC
Juneau,AK
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Original Message:
Sent: 10-25-2018 07:22 AM
From: Randy Lewis
Subject: Disclosing PHI or previous CE

​David:
My question is: "What is CE2's involvement in this matter?"

If they now hold the patient record, then CE2 should get the authorization. However, if CE1 holds the record, then the authorization should go to the physician who used to work at CE1 AND a separate authorization (for access to the record) should go to CE1.

Just my two cents...

------------------------------
Dr. Randy Lewis, LMFT, CHPC
HIPAA Privacy Officer
Orange County Government
Orlando, FL

Original Message:
Sent: 10-24-2018 04:27 PM
From: David Garrison
Subject: Disclosing PHI or previous CE

Hi all, wondering what is needed for this scenario:  Provider use to work at CE1, but now works at CE2.  Provider is being asked to testify on behalf of patient they saw when working at CE1.  Provider is willing to testify and patient is willing to give authorization to provider.   Since provider is working at CE2, does CE2 get the authorization?  Does CE1 get it?  Does provider send it to CE1 and get "ok'd" to disclose their PHI?

Thanks

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

Then I would think CE1.

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Carl Russell
Compliance Analyst
Delta Dental of Idaho
Boise,ID

Anything I say is my sole opinion and not of my company.
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Original Message:
Sent: 10-25-2018 12:45 PM
From: David Garrison
Subject: Disclosing PHI or previous CE

Randy, the provider now works at CE2.  The patient is a patient of CE1 and saw the provider while they worked at CE1.  CE2 has no PHI belonging to the patient, other than what is in the "head" of the provider.

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

Original Message:
Sent: 10-25-2018 07:22 AM
From: Randy Lewis
Subject: Disclosing PHI or previous CE

​David:
My question is: "What is CE2's involvement in this matter?"

If they now hold the patient record, then CE2 should get the authorization. However, if CE1 holds the record, then the authorization should go to the physician who used to work at CE1 AND a separate authorization (for access to the record) should go to CE1.

Just my two cents...

------------------------------
Dr. Randy Lewis, LMFT, CHPC
HIPAA Privacy Officer
Orange County Government
Orlando, FL

Original Message:
Sent: 10-24-2018 04:27 PM
From: David Garrison
Subject: Disclosing PHI or previous CE

Hi all, wondering what is needed for this scenario:  Provider use to work at CE1, but now works at CE2.  Provider is being asked to testify on behalf of patient they saw when working at CE1.  Provider is willing to testify and patient is willing to give authorization to provider.   Since provider is working at CE2, does CE2 get the authorization?  Does CE1 get it?  Does provider send it to CE1 and get "ok'd" to disclose their PHI?

Thanks

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