Our Privacy Policy
page 4
Disclosure for Other Persons' TPO
Our agency also may disclose protected health information to others for their treatment, payment and health care operations as follows:
- Our agency may disclose protected health information to another health care provider for its treatment activities.
- Our agency may disclose protected health information to a health plan or another health care provider for its payment activities.
- Our agency may disclose protected health information to a health plan or another health care provider for its health care operations, but only if
- i. both our agency and the other party have, or had, a relationship with the consumer whose information is being disclosed;
- ii. the protected health information being disclosed pertains to that current (or previous) relationship; and
- iii. the disclosure is for certain limited health care operations activities, including conducting quality assurance and/or quality improvement activities, education or training of students and other staff, reviewing the competence or qualifications, or the performance, of health care professionals, accreditation, licensing, credentialing, and fraud and abuse detection or compliance activities.
Disclosures of protected health information for others' payment activities or health care operations are subject to the HIPAA Privacy Regulations' minimum necessary standard.
C. De-identified Information Not Subject to TPO Restriction
Protected health information is considered "de-identified" when all elements that have the potential to identify the consumer have been removed. Protected health information will be deemed de-identified when (i) a person with appropriate knowledge and experience in scientific and statistical principles for de-identifying information has determined that there is a very small risk that that the information can be used to identify the consumer and has documented the analysis that justifies that decision, or (ii) certain specific identifying elements regarding the consumer and his or her relatives, employers and household members have been removed and the remaining information cannot be used to identify the consumer.
The elements that must be removed include the following:
- names;
- all geographic subdivisions smaller than a state, including street address, city, county, precinct, zip code and their equivalent geocodes;




