Accounting for Billing Disclosures

Background

HIPAA requires that we track disclosures of PHI for purposes other than releases for TPO or releases with patient authorization except in limited circumstances. The P of TPO has some instances which could lead to disclosures requiring accounting and others which would not. The decision is based on whether or not we are disclosing based on inaccurate information provided by the patient/provider vs. errors in the processing, whether intentional or not.

Examples:

Cases where the disclosure would need to be listed in the accounting for disclosures log:

• Clinical trial procedures incorrectly billed to insurance instead of to sponsor
• Computer error in batch processing either through programming error or any other computer glitch
• Mailing errors such as mismatch of letter and envelope

Cases where the disclosure would not need to be listed in the accounting for disclosures log:

• Patient/hospital provides inaccurate information
• Patient has changed coverage and has not provided updated information