HIPAA Privacy and Michigan Confidentiality Laws
Sets out how the Agency, as a HIPAA covered entity, protects the privacy of every patient’s health information: the Privacy Official and complaint contact (45 CFR §164.530(a)), minimum necessary and role-based access, the uses and disclosures the Agency makes with and without a patient’s authorization, the stricter Michigan and federal rules for HIV, mental health and substance use disorder information, the Notice of Privacy Practices and its acknowledgment (Form MI-HH-PRV-01-A), patients’ privacy rights, safeguards in the home and in the field, privacy complaints, sanctions, mitigation and non-retaliation.
- Policy number
- MI-HH-PRV-01
- Version
- 1.0
- Main rule
- 45 CFR Part 164, Subpart E
- Library
- Michigan home health · 57 policies
- Category
- Privacy
- Sections
- 26
In short
- Share patient information only for care, billing or Agency work, and only as much as the task needs.
- Before talking with family or friends, check who the patient has said may be told. Never discuss a patient with neighbors or unknown callers.
- Give the Notice of Privacy Practices at the first visit and get the patient’s signature on the acknowledgment, or write down why not.
- HIV, mental health and substance use information has extra protection. Ask the Privacy Official before sharing it.
- Abuse reports required by law are never delayed for privacy reasons.
- Report any privacy mistake or complaint to Lee Sample the same day. No one is punished for complaining.
What's inside
26 sections. The full text comes with the One-time Policy Pack.
- Terms of Reference
- 1. Purpose
- 2. Scope
- 3. Definitions
- 4. Policy Statement (45 CFR Part 164, Subpart E)
- 5. Privacy Official and Contact Person
- 6. Minimum Necessary and Role-Based Access
- 7. Uses and Disclosures
- 7.1 Family, Friends and Others Involved in Care
- 7.2 Authorizations
- 7.3 Business Associates
- 8. Michigan and Federal Rules That Give More Protection
- 9. Notice of Privacy Practices
- 9.1 Federal Changes to Watch
- 10. Patients’ Privacy Rights
- 11. Everyday Safeguards in the Home, in the Car and in the Office
- 12. Privacy Complaints
- 13. Sanctions
- 14. Mitigation
- 15. Responsibilities
- 16. Records and Compliance Monitoring
- 17. Staff Training
- 18. References
- 19. Related Policies and Forms
- 20. Approval
- 21. Revision History
An inspector may ask
- Who is your privacy official, and where is that designation documented?
- Show me your Notice of Privacy Practices and the signed acknowledgment for this patient. Where is the notice posted?
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