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  1. Who can handle a complaint on a possible violation of privacy?

  2. After the initial training, how often do I have to train office personnel on privacy issues?

  3. Do I have to monitor daily?

  4. What if the information requester is the medical board or a police officer?

  5. Who determines the “minimum necessary” when I receive a request for protected health information (PHI)?

  6. Do I, as the privacy officer, have to review all requests for protected health information (PHI)?

  7. We occasionally need to courier protected health information (PHI) such as original x-rays to another location. Do we need a business associate agreement with each courier service?

  8. As we develop additional contacts that require a business associate agreement, what exposure do we have if the business associate inappropriately releases protected health information (PHI)?

  9. Am I required to have business associate contracts with bio-medical equipment technicians or contractors such as plumbers, electricians, or office machines repair individuals who provide repair services?

  10. Mr. Green calls for a prescription renewal for his wife, Betty. He wants us to leave a message on his answering machine when the renewal has been called in to the pharmacy and what drug has been prescribed. He will be at work and not accessible by phone. His wife is too ill to take calls and he wants her to rest without trying to answer the phone. Is it okay to leave a message on his answering machine and can we tell him the name of the drug prescribed?

  11. Jill, one of the pharmaceutical reps. that service our office, is bringing in lunch for the doctors and staff. She will be providing a brief lecture on a new antibiotic. We usually have the lunches in our break room where the nurses are working on charts and next to the area our doctors dictate their visit notes. Is it okay to still have the rep. lunches (Jill always seemed very trustworthy)?

  12. Connie is my front desk receptionist. She has been with us for 10 years and has completed the HIPAA training. She continues to discuss with patients how they are doing and references the reason for their visit within earshot of the waiting room. Patients love her and I have not had a complaint. Is this a concern?

  13. Do I need to have a signed authorization to send records to another physician when I refer a patient to him/her?

  14. Do I need to remodel my office so no one can see charts or overhear conversations?

  15. Can I still fax things to other offices?

  16. Can I leave information on a patient’s answering machine?

  17. An insurance company wants to evaluate our practice, including looking at a sample of our medical records. Do I need to get an authorization from the patient if his/her chart will be among those reviewed?

  18. Mr. Wheeler is a regular patient who comes in at least every month or so. He is very hard of hearing and we have to shout in order for him to understand. Are we breaching his privacy if other patients overhear something about his condition due to the loud conversational level?

  19. The office manager’s daughter volunteers in our office during winter break. She helps us with filing. Do we need a business associate agreement with her since she has access to protected health information (PHI)?

   
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