Comment on FR Doc # 2010-10054

Documenting every disclosure including treatment, payment & operations will be a huge burden on facility staff. HIPAA was for administrative simplification (we thought). If our systems do not log all of these disclosures electronically (they certainly don't now) they would all have to entered manually - this means every claim sent, every document that goes to another healthcare provider, every birthcertificate logged, etc. etc. etc. If the system does log everything automatically (every touch of the record as some do) and the patient asked for an accounting - we would have to print the accounting after hours because it would be voluminous. We would then not have enough staff to sit with the patient and go through the entire accounting and answer questions. Patients know we submit claims, information to other providers is for a followup appointment or at the patient's request, we have lto comply with state and federal reporting laws, so why give us the burden of documenting all of that?