TITLE:

RELEASING PROTECTED HEALTH INFORMATION FOR PURPOSES OF ORGAN, EYE, OR TISSUE DONATION OR TO CORONERS, MEDICAL EXAMINERS, OR FUNERAL DIRECTORS

POLICY:
Columbia University Medical Center will release Protected Health Information (PHI) without the patient's authorization to facilitate organ, eye, and tissue procurement, banking, or transplantation, or upon request from a coroner, medical examiner, or funeral director.

PURPOSE
Columbia University Medical Center is committed to protecting patient privacy as mandated by city, state, and federal laws and regulations, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA), and will generally not release a patient's PHI without first obtaining the patient's authorization. The purpose of the Policy is to describe a set of specific circumstances under which Columbia University Medical Center will release a patient's PHI without the patient's authorization.

PROCEDURES:

1. Releases of PHI to facilitate organ, eye, and tissue donations. Columbia University Medical Center will disclose a patient's PHI without the patient's written authorization to facilitate organ and tissue procurement, banking, and transplantation.
1. Prior to making the disclosure, Columbia University Medical Center will verify the identity and authority of the individual making the request.



2. Columbia University Medical Center will disclosure only the minimum amount of PHI necessary to meet the purpose of the request.



3. Specially protected PHI, including HIV/AIDS information and genetic information, will be disclosed in accordance with their respective Policies.



2. Releases of PHI to coroners and medical examiners. Columbia University Medical Center will disclose a patient's PHI to coroners and medical examiners for the purposes of identifying a deceased person, determining a cause of death, or other duties as authorized by law.
1. Prior to making the disclosure, Columbia University Medical Center will verify the identity and authority of the individual making the request.



2. Columbia University Medical Center will disclosure only the minimum amount of PHI necessary to meet the purpose of the request.



3. Specially protected PHI, including HIV/AIDS information and genetic information, will be disclosed in accordance with their respective Policies.



3. Releases of PHI to funeral directors. Columbia University Medical Center will disclose a patient's PHI to funeral directors as necessary to carry out the funeral directors' responsibilities and duties.
1. A patient's PHI may be disclosed to a funeral director prior to, and in reasonable anticipation of, the patient's death.



2. Prior to making the disclosure, Columbia University Medical Center will verify the identity and authority of the individual making the request.



3. Columbia University Medical Center will disclosure only the minimum amount of PHI necessary to meet the purpose of the request.



4. Specially protected PHI, including HIV/AIDS information and genetic information, will be disclosed in accordance with their respective Policies



4. Documentation of disclosures required. Documentation of any disclosures made pursuant to this Policy will be made and included in the patient's medical record. (Refer to the Accounting of Disclosures Policy for a description of the required documentation.)



5. Questions. Questions about whether a disclosure may be made to facilitate organ, eye, and tissue donation or to coroners, medical examiners, or funeral directors should be directed to the employee's supervisor or the HIPAA Privacy Officer.



6. Definitions

Protected Health Information is information about a patient, including demographic information that may identify a patient, that relates to the patient's past, present or future physical or mental health or condition, related health care services or payment for health care services.

RESPONSIBILITY:         HIPAA Privacy Officer, Departments