Ms. LaBlanc asked a question about faxing PHI without a cover sheet because of undue burden on staff.
1. Ms. LaBlanc should check her fax machines for the ability to retain information, and then check to see if the fax machines are leased or owned by her facility.
The fax machines have the capability to print out a confirmation of the document being sent, which would show all of the PHI (instead of the cover sheet) because most fax machines retain a memory of the first page faxed.
Without a cover sheet she would have to assure that the 'confirmation report' is in the hands of those who have a need to know', and when she 'gives back' or replaces the machine that the memory is not retained.
2. The fax cover sheet also serves to give notice to the recipient that if this is not the correct recipient, please contact ____, and that the incorrct recipient should destroy the document(s); basically a standard HIPAA statement.
3. Overall, Ms. LaBlanch should alanyze the risks that her fax represents, and report back to the group of physicians whether the facility is willing to take the risks....but have a disclosure log ready to go.
Linda Wolverton