TITLE:

OWNERSHIP AND CONTROL OF ORIGINAL RECORDS CONTAINING PROTECTED HEALTH INFORMATION

POLICY:
Original records that contain Protected Health Information (PHI) that are created or collected by and maintained at Columbia University Medical Center are the property and confidential asset of the health care provider with whom the patient has a physician/patient relationship.

PURPOSE :
Columbia University Medical Center is committed to protecting the confidentiality of records, documents, and information about its patients as mandated by city, state, and federal laws and regulations, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

This Policy describes the procedures by which Columbia University Medical Center will help to assure confidentiality of patients' records.

PROCEDURES:

1. Access to a patient's records. Columbia University Medical Center will limit access to a patient's records to:
1. the patient;



2. the patient's health care providers;



3. Columbia University Medical Center personnel for treatment, payment, and health care operations purposes; and



4. individuals and entities who are authorized by law or by the patient's written authorization to access the patient's records.


2. Removal of a patient's records from Columbia University Medical Center.
1. Columbia University Medical Center prohibits removing original records from the premises of Columbia University Medical Center.



2. Columbia University Medical Center permits copying records that are needed off Columbia University Medical Center premises. Copies of original records will be protected and disposed of in accordance with Columbia University Medical Center policies and procedures.



3. If a court orders production of a patient's original records, and original records are taken off the premises of Columbia University Medical Center to comply with the court order, a records custodian or other representative of Columbia University Medical Center will accompany the original records and ensure their return to Columbia University Medical Center.


3. Disposition of original records upon departure of a health care provider.
1. If a health care provider retires, his/her patients will be notified. A copy of the patient's record will be forwarded to the new health care provider upon receipt of a written patient authorization.



2. If a health care provider leaves Columbia University Medical Center to go to a new practice, his/her patients will be notified of his/her departure. It is the responsibility of the departing health care provider to arrange for and copy the records of his/her patients who elect to continue to receive care from the departing health care provider at his/her new practice.


4. 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:         Departments, HIPAA Privacy Officer