Purpose:
Track non-standard PHI disclosures under §164.528.
Instructions:
Record all non-standard disclosures.
Retain logs for six years.
Audit regularly for accuracy.
Secure and restrict access.
Optional Template:
A disclosure log template is provided with predefined fields for tracking date, recipient, purpose, and scope of disclosures.
Purpose:
This template is used to document and track disclosures of Protected Health Information (PHI) for purposes other than treatment, payment, or healthcare operations. Maintaining a disclosure log ensures transparency and compliance with HIPAA §164.528.
Instructions for Use
Complete the Template for Every Disclosure:
Use this log for every instance of PHI disclosure that falls outside standard operations such as treatment, payment, or healthcare processes.Retain for a Minimum of Six Years:
In compliance with HIPAA, retain completed logs securely for six years.Audit Regularly:
Regularly review logs to ensure accuracy and consistency. Any discrepancies should be addressed immediately.Secure Documentation:
Store the logs securely to prevent unauthorized access, and ensure access is limited to authorized personnel only.
Disclosure Log
Field | Description |
Date of Disclosure | The date the PHI was disclosed. |
Recipient Name | Name of the individual, organization, or entity receiving the PHI. |
Recipient Organization | (Optional) Organization to which the recipient belongs (if applicable). |
Recipient Contact Info | Phone number or email address for the recipient (optional but recommended). |
Purpose of Disclosure | Brief description of why the PHI was disclosed (e.g., legal request, research). |
Type of PHI Disclosed | Description of the information disclosed (e.g., medical records, billing data). |
Legal Basis | Reference to the authorization or regulation permitting the disclosure. |
Disclosure Method | Indicate how the PHI was disclosed (e.g., verbal, electronic, paper). |
Requestor Name | Name of the individual or entity requesting the disclosure (if applicable). |
Notes/Comments | Additional information or observations about the disclosure.
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