Comment on FR Doc # 2010-10054

Document ID: HHS-OCR-2010-0009-0007
Document Type: Public Submission
Agency: Department Of Health And Human Services
Received Date: May 04 2010, at 11:34 AM Eastern Daylight Time
Date Posted: May 5 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: May 3 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: May 18 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80ae6639
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The Village is a comprehensive community based substance abuse treatment center serving 1000 clients/year. 95% of information disclosures are either TPO or consented. In fact, as substance abuse treatment centers that receive any federal funding assistance also are governed by 42CFR part 2, almost all disclosures are consented/authorized in writing. It would be an unwarranted burden to require the agency to maintain disclosure records on information for which the client has given authorization. This would requre a financial burden of purchasing or developing a database to track each disclosure made throughout the entire agency--to private community physicians, hospitals, department of vocational rehabilitation, courts, probation officers, etc. The clients already know about any disclosures. It is an undue burden to have to log each of these, in terms of $, but even more in terms of staff time that could be used for more productive direct service.

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