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.
Comment on FR Doc # 2010-10054
This is comment on Proposed Rule
HIPAA Privacy Rule Accounting of Disclosures under the Health Information Technology for Economic and Clinical Health Act: Request for Information
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