Nov

02

HIPAA Q&A: Anticoagulation clinics

By Chris Apgar

Q. An anticoagulation clinic might offer group classes for newly enrolled patients. The classes would include the effects of the patient’s diet and over-the-counter medications, the effects of prescription medication on anticoagulation medication dosing, safety measures, review of conditions requiring anticoagulation medication, and potential complications and side effects of anticoagulation therapy.

If we don’t discuss specific individual information in the group setting, are we still at risk for a potential HIPAA violation?

A. As long as you inform the newly enrolled patients in advance that other patients requiring anticoagulation therapy will attend voluntarily, you will not be in violation of the HIPAA privacy rule. Mandatory attendance could represent a HIPAA privacy rule violation because you would be exposing patients to other patients with similar conditions. Patients’ voluntary attendance indicates to others present that they or their family members take anticoagulation medication.

Editor’s note: Chris Apgar, CISSP, answered this question. This is not legal advice. Consult your attorney regarding legal matters.