Privacy Officer's Roundtable

Patient Right of Access audit

  • 1.  Patient Right of Access audit

    Posted 10-22-2020 08:04 AM
    Hello everyone - with the OCR's focus on the patient's right to access and the recent settlements, I have been asked to review our organization's compliance with this requirement.  I am thinking to start small and keep it to requests for their own PHI (whether by the patient or a representative) and have a framework to start, but just wondering if anyone else has done something similar.  Who was included and what was actually reviewed?  Thanks!

    Lance Smith
    Privacy Officer
    St. Peter's Health Partners

    2020 SCCE Membership

  • 2.  RE: Patient Right of Access audit

    Posted 10-22-2020 08:17 AM
    A very good section within the Privacy Rule to focus my opinion.  Another is the amendment of PHI process given the info blocking and Patient Access Final rule which were recently posted.  Will certainly have applicability to access as well.

    Posted: 5:15 AM AZ time

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  • 3.  RE: Patient Right of Access audit

    Posted 10-23-2020 08:16 AM
    You'll need to look at your ROI policy and ask around. There could be multiple stakeholders at your organizations involved in ROI beyond the HIM Department or a third party processor. I would start there and then see if the policy is being followed.

    Brenda Manning J.D., C.H.C., C.H.P.C.
    Privacy Director
    Privacy Officer
    Carilion Clinic

    The views expressed herein are my own and do not represent those of my employer. They are not meant to constitute legal advice or create an attorney-client relationship.

    2020 SCCE Membership