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ACCOUNTING FOR DISCLOSURES QUICK REFERENCE The HIPAA Privacy Rule requires covered entities to account for certain disclosures of protected health information. This accounting will need to include many things that are in your Notice of Privacy Practices (NPP), especially the ones that may be disclosed without authorization. The following is a list of disclosures that must be logged on the “PHI Disclosure Log.” Health Oversight - Department of Inspection and Appeals Locating suspects, fugitives, witnesses – to law enforcement Suspicious deaths – to law enforcement, medical examiner Abuse, adult and child – to law enforcement, Division of Family Services Birth reporting to State Communicable disease reporting Crime on premises- to law enforcement Crime victims- to law enforcement Death certificates, death notification Employer for work related illness or injury Significant exposure to communicable disease- to EMS FDA (Food and Drug Administration) Foreign military personnel Funeral director/homes Government-required releases (trauma registry, birth defect registry, what may be mandated by your state) Injury reporting - to law enforcement Medical Examiner Organ donor services Public Health Issues Research (without authorizations) Subpoenas, court orders, discovery request or other lawful process (unless authorization is provided) U.S. Embassies Contractors/ Business Associates (if not for TPO) Vendors (if not for TPO) Just because examples of disclosures are listed in the NPP doesn't mean covered entities don't have to account for them on an individual basis. This is an important part of your HIPAA compliance that could be easily forgotten. Each disclosure must be logged and the patient has a right to that accounting. There are, however, a couple exceptions. If a disclosure is made to a health oversight agency or law enforcement official a covered entity must temporarily suspend an individual’s right to receive an accounting, if such agency or official submits such a written statement. The written statement must note that any accounting to the individual would be reasonably likely to impede the agency’s activities and it must specify the time for which such a suspension is required.