tci Medicare Compliance & Reimbursement - 2020 Issue Q2
HIPAA: Obtain Authorizations Before Cameras Roll
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Article Overview
This article covers HIPAA privacy requirements during the COVID-19 era, with emphasis on when healthcare organizations need patient authorization before allowing media or film crews access to areas where protected health information may be accessible. It also discusses the distinction between consent and authorization, general OCR guidance, and the standard elements required for valid HIPAA authorization forms. The content is relevant to compliance staff, providers, administrators, and anyone responsible for privacy practices in covered entities.
Why This Topic Matters
Healthcare organizations may face privacy risk when media presence intersects with patient care areas, especially during public health emergencies. Understanding the general HIPAA authorization framework helps organizations support patient privacy and maintain compliance efforts.
Article Sections
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Privacy requirements still matter in a pandemic
Introduces HIPAA privacy concerns arising from increased media activity in healthcare settings during the COVID-19 public health emergency. It frames the article’s focus on patient privacy, covered entities, and OCR reminders.
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‘Consent’ and ‘Authorization’ Are Not the Same
Explains the general distinction between routine patient consent and written authorization under HIPAA. This section addresses how the article uses those terms in the context of privacy and disclosure.
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See the Feds’ Reasoning for Extra Guidance
Summarizes why OCR issued additional guidance and how the article describes media access, facility privacy concerns, and related compliance reminders. It also discusses broad safeguards and the role of facility policies.
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Add ‘Core Elements’ to HIPAA Authorization Forms
Reviews the article’s discussion of the general standards that make a HIPAA authorization form valid. It covers the broad categories of form content and documentation expectations.
What You Will Learn
- How HIPAA privacy concerns can arise when media access occurs in healthcare facilities
- The difference between patient consent and HIPAA authorization in general terms
- Why OCR issued additional guidance during the COVID-19 public health emergency
- What broad categories of information are expected in valid HIPAA authorization forms
- What compliance staff should consider when reviewing privacy procedures and authorization practices
Who Should Read This
- Healthcare compliance professionals
- Privacy officers
- Hospital administrators
- Providers and facility managers
- Health information management staff
- Legal and compliance teams
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