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HIPAA Q&A: Disclosure forms

Q. A sister company has created a wellness walking trail through a medical record storage warehouse. Must employees of the sister company complete confidentiality/disclosure forms?

A. No. Employees using the wellness walking trail should not provide unmonitored access to medical records. If they simply walk through storage areas during times when staff members are present, signed confidentiality agreements are not necessary; they should not have access to medical records. Obviously, employees should not be able to access the walking trail through record storage areas after hours when staff members are not present.

Editor’s note: Mary D. Brandt, vice president, health information management, at Scott &White Healthcare, Temple, TX, answered this question. She is a nationally recognized expert on patient privacy, information security, and regulatory compliance, and her publications provided some of the basis for HIPAA’s privacy regulations. Advice given is general. Readers should consult professional counsel for specific legal, ethical, or clinical questions.