Checking in on accounting of disclosures

摘要

ACCOUNTING OF DISCLOSURES (AOD) is one "patient right" listed within the HIPAA Privacy Rule. Since the rules were implemented in 2003, AOD has been a topic of much discussion but has not generated much regulatory action from the US Department of Health and Human Services' (HHS) Office for Civil Rights (OCR) or from patients requesting fulfillment of this right. Few facilities receive these types of requests, and many patients aren't aware they have this right or what to expect from a request. Under the original HIPAA Privacy Rule an individual has the right to receive an accounting of disclosures on protected health information (PHI) created by a covered entity up to six years prior to the date of the requested disclosure. There tends to be confusion within HIPAA-covered entities and their business associates about what must be listed in an AOD report with relation to a patient's PHI designated record set. The HIPAA rule changes proposed by the 2009 HITECH Act, which propose a major modification to AOD, has only further complicated individual's interpretations of the law.