PIC falls under the umbrella of a “health care provider that transmits health information in electronic form in connection with a transaction for which the Secretary of HHS has adopted standards under HIPAA” (see document Summary of the HIPAA Security Rule _ HHS.gov.pdf). PIC is held to HIPAA security standards. PIC’s HIPAA FAQ form covers our HIPAA and Notice Privacy Practices, which must be reviewed and signed annually by families. Please also see the reference document Understanding Patients’ Health Information Rights for PIC’s responsibility for use and disclosure of PHI.
HIPAA Practice/Legal Name Policy
PIC does not collect birth certificates for children in its care. Instead, the child’s legal name is confirmed by the parent or caregiver at the time of intake. The legal name is defined as the name that appears on the birth certificate, which may differ from the name commonly used by the parent or caregiver. PIC often receives referrals for infants whose legal name includes “Baby Boy” or “Baby Girl” as their designated first name. In all cases, the legal name provided will be entered into RainTree exactly as it appears on the birth certificate, and as reported by the caregiver.
Designating a Nickname or Given Name
Until the child has change of birth certificate, the child can have a nickname or given name in quotes in RainTree such as Baby Girl “Birdie” Smith
Establishing an Alias in RainTree
If a provider is informed that a child’s name has been legally changed, the provider will inform the PIC Data Entry team, who can establish and Alias in the electronic Health record. PIC will request documentation of this change; however it is not required.
Guardianship
PIC does not require documentation of legal guardianship. In cases of OCS involvement, PIC will accept a change in placement form, paired with an ROI sent to OCS (Change of Placement with ROI- fillable). Due to “Unreasonable Measures” PIC does not require guardians to have a signed ROI in place to receive the minor’s records themselves, only if being sent to a 3rd party.
A summary of PIC’s HIPAA procedures includes, but is not limited to:
- Client Legal Name Change and Documentation.docx
- Written Disclosures: Rain Tree automatically tracks written disclosures when records are faxed or emailed through Rain Tree. This is found in the Communication tab of the Chart under “Disclosures” including date/time, what records are sent, and reason for the disclosure.
- Communication Log Procedure.docx
- Release of Information Procedure.docx
- Medical Records Requests Admin Procedure for Processing Record Requests.docx
- Corrections may be made to the record Correction to the record per parent request