July 2, 2019

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.


The information contained in this article is provided as general guidance and may be affected by changes in law or regulation. This article is not intended to replace or substitute for accounting or other professional advice. Please consult a CBIZ professional. This information is provided as-is with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.

Accelerated Recovery Resources

Access articles and tools to help your business generate cash, improve leverage, and align & transform as you recover from the pandemic.

COVID-19 Resources

Access all COVID-19 related articles to help your business respond to the pandemic.

Insights in Your Inbox