Pharmacy Chain Enters into Business Associate Agreement with Law Firm
Pharmacy Chain Enters into Business Associate Agreement with Law Firm
Covered Entity: Pharmacy Chain
Issue: Impermissible Uses and Disclosures; Business Associates
A complaint alleged that a law firm working on behalf of a pharmacy
chain in an administrative proceeding impermissibly disclosed the PHI of
a customer of the pharmacy chain. OCR investigated the allegation and
found no evidence that the law firm had impermissibly disclosed the
customer’s PHI. However, the investigation revealed that the pharmacy
chain and the law firm had not entered into a Business Associate
Agreement, as required by the Privacy Rule to ensure that PHI is
appropriately safeguarded. Without a properly executed agreement, a
covered entity may not disclose PHI to its law firm. To resolve the
matter, OCR required the pharmacy chain and the law firm to enter into a
business associate agreement.
| National Pharmacy Chain Extends Protections for PHI on Insurance Cards Covered Entity: Pharmacies Issue: Impermissible Uses and Disclosures; Safeguards A pharmacy employee placed a customer's insurance card in another customer's prescription bag. The pharmacy did not consider the customer's insurance card to be protected health information (PHI). OCR clarified that an individual's health insurance card meets the statutory definition of PHI and, as such, needs to be safeguarded. Among other corrective actions to resolve the specific issues in the case, the pharmacy revised its policies regarding PHI and retrained its staff. The revised policies are applicable to all individual ...read more |
| No Business Associate Agreement? $31K Mistake The Center for Children’s Digestive Health (CCDH) has paid the U.S. Department of Health and Human Services (HHS) $31,000 to settle potential violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule and agreed to implement a corrective action plan. CCDH is a small, for-profit health care provider with a pediatric subspecialty practice that operates its practice in seven clinic locations in Illinois. In August 2015, the HHS Office for Civil Rights (OCR) initiated a compliance review of the Center for Children’s Digestive Health (CCDH) following an initiation ...read more |
| National Pharmacy Chain Extends Protections for PHI on Insurance Cards Covered Entity: Pharmacies Issue: Impermissible Uses and Disclosures; Safeguards A pharmacy employee placed a customer's insurance card in another customer's prescription bag. The pharmacy did not consider the customer's insurance card to be protected health information (PHI). OCR clarified that an individual's health insurance card meets the statutory definition of PHI and, as such, needs to be safeguarded. Among other corrective actions to resolve the specific issues in the case, the pharmacy revised its policies regarding PHI and retrained its staff. The revised policies are applicable to all individual ...read more |
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