Privacy and Health Care Coordination Clarified
The HHS Office for Civil Rights issued a set of FAQs on June 26, 2019 relating to the privacy and permissible sharing of protected health information (PHI) in accordance with the HIPAA privacy and security laws.
- One FAQ clarifies that PHI can be shared between health plans for purposes of proper administration of coordination of benefits.
- Another FAQ clarifies that information can be shared for health coverage coordination in certain limited marketing situations, without written authorization.
These clarifications are not surprising in that HIPAA allows free flow of PHI for health plan operations. Importantly, if PHI is to be shared in this manner, it is subject to the minimum necessary requirement, i.e., only the minimum amount of information necessary to achieve the goal can be shared.
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