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Title: Disclosures of Personally Identifiable Health Information to Business Associates
Subject: Office of Compliance & Corporate Integrity (OCCI)
Policy No: OCCI: 2013: P08
Applies: RowanSOM
Issuing Authority: Rowan President & RowanSOM Dean
Responsible Authority: RowanSOM Chief Compliance and Privacy Officer & Rowan Security Officer
Adopted: April 14, 2003
Amended: July 1, 2013.
Reviewed: Dec 30, 2014
I. PURPOSE
To assure compliance with the requirements of the Health Insurance Portability and Accountability Act (HIPAA) of 2004, Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009 and the Omnibus Privacy Final Rule of 2013 in relation to disclosures of Protected Health Information (PHI) and to entering into contracts with business associates.
II. ACCOUNTABILITY
Under the direction of the President, the Deans, Executive Vice President for Administration and Strategic Planning, Executive Vice President for Academic and Clinical Affairs, Chief Compliance and Privacy Officer, Vice President for Finance and CFO and General Counsel shall ensure compliance with this policy.
III. APPLICABILITY
This policy shall apply to disclosures to business associates of health information that is generated during provisions of health care to patients in any of the RowanSOM's patient care units, patient care centers of faculty practices as well as Human Subjects research under the auspices of RowanSOM or by any of its agents in all RowanSOM, Units, Departments and University owned or operated facilities.
IV. DEFINITIONS
A. "Protected Health Information (PHI)" - Protected health information means individually identifiable health information that relates to the past, present or future physical or mental health or condition of an individual, the provision of health care to an individual or the past, present or future payment for the provision of health care to an individual and identifies or could reasonably be used to identify the individual. PHI of a decedent, who has been deceased for more than 50 years, is no longer considered protected PHI [160.103 and 164.502(f)].
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