Deborah,

You are limited in the information you may provide to another CE for the
purpose of health care operations.  You must both have a relationship with
the individual (patient), and it must be for the purposes stated in (1) and
(2) of the health care operations definition.  For these purposes, you can
disclose without authorization.  If you are disclosing PHI for other health
care operations, (3) - (6) of the definition,  or the requesting CE does
not have a relationship with the patient, authorization is required or you
can provide the limited data set (as long as you obtain a data use
agreement.)

Nancy Vogt
Manager, Privacy Compliance/Chief Privacy Officer
Aurora Health Care
Milwaukee, WI


                                                                                       
                                                  
                      Deborah Campbell                                                 
                                                  
                      <DCampbell@dominion        To:       [EMAIL PROTECTED]            
                                                  
                      dental.com>                cc:                                   
                                                  
                                                 Subject:  PRIVACY: Limited Data Set   
                                                  
                      08/30/2002 10:49 AM                                              
                                                  
                                                                                       
                                                  
                                                                                       
                                                  









I'm trying to sort out the new Privacy modifications and need some help
with Limited Data Sets - or LDS as I like to call them.


I thought that a Covered Entity could release PHI for Operations. But
according to the new modifications, it says that a CE may use or disclose a
LDS only for the purpose of research, public health, or health care
operations.


Does this mean that we are only allowed to release LDS for Operations, or
can we release PHI for Operations?


Thanks,
Deborah Campbell
Compliance Coordinator


Dominion Dental Services, Inc.
115 South Union Street, Suite 300
Alexandria, Virginia 22314


Phn: (703) 518-5000 ext. 3035
Fax: (703) 518-8849
Toll Free:  888-518-5338
Email: [EMAIL PROTECTED]


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