E/M Coding Alert - 2020 Issue 4
Privacy: Know These PHI Disclosure Essentials
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Article Overview
This article explains how HIPAA privacy obligations continue to apply during a public health emergency, including emergency situations tied to disease outbreaks and other disruptions. It summarizes general OCR guidance on protected health information disclosures, the roles of covered entities and business associates, and the broad categories of circumstances where disclosure without authorization may be permitted. The piece is intended for healthcare providers, compliance staff, and privacy professionals who need a high-level refresher on emergency privacy rules and patient confidentiality expectations.
Why This Topic Matters
Privacy practices can change operationally during emergencies, but HIPAA obligations do not disappear. Understanding the general boundaries of permitted disclosures helps organizations respond to public health needs while continuing to protect patient privacy.
Article Sections
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Emergency Privacy Reminder
Introduces the article’s focus on privacy policy review during emergency situations, natural disasters, and disease outbreaks. It frames the discussion around public health emergency conditions and patient privacy obligations.
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HHS Public Health Emergency and OCR Bulletin
Summarizes the public health emergency context and the federal privacy guidance issued in response. It covers the general relationship between the emergency declaration, HIPAA, and OCR’s clarification of privacy expectations.
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When PHI May Be Shared Without Authorization
Outlines the broad categories of circumstances discussed in the guidance where disclosures may be permitted without patient authorization. The section groups the discussion around treatment, public health activities, family and friends, and imminent threat situations.
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Caution on Patient Privacy
Highlights the reminder that emergency-related public health reporting does not eliminate privacy protections. It reinforces that confidentiality considerations still apply even when disclosures are allowed in limited circumstances.
What You Will Learn
- How HIPAA privacy obligations continue during a public health emergency
- What types of OCR guidance are discussed for emergency disclosures
- Which general categories of situations may permit disclosure without authorization
- Why privacy protections still matter during public health reporting and outbreak response
Who Should Read This
- Healthcare providers
- Practice managers
- Compliance staff
- Privacy officers
- Revenue cycle and administrative staff involved in HIPAA compliance
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