In its third release of HIPAA guidance over the past few weeks, the Department of Health and Human Services (HHS) released“The Real HIPAA: Care Coordination, Care Planning, and Case Management Examples” to assist covered entities and business associates in determining what disclosures of protected health information are permitted under HIPAA.
The blog post gives examples of disclosure of protected health information for care coordination (e.g. a hospital discharging a patient to a rehabilitation facility); care planning by a provider (e.g. hiring a vendor to provide the services, with a business associate agreement in place); and case management by a payer (e.g. the payer hires a health management company to provide nutritional advice to its members with a business associate agreement in place).
The guidance provided by HHS is easy to read and understand and is very helpful with practical examples that providers can understand. We will continue to watch for these helpful tips and keep you apprised as they are published.