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Greg,
Personal representatives and confidential
communications are two separate requirements. When an individual
designates a personal representative, the covered entity must treat the personal
representative as the individual for purposes of the Privacy Regulations.
In other words, any correspondence that would normally go to the individual
should instead go to the personal representative. So, in that case, the
covered entity would need to maintain both the addresses of the individual and
the personal representative. The confidential communications provision
allows the individual to request that communications be sent to the individual
either at an alternative location or by alternative means. In this case,
the covered entity would need to be able to track the individual's primary
address and the alternative address at which they request to receive
confidential communications.
Regards,
Connie Hein
Paramore Consulting, Inc.
e-commerce for healthcare
----- Original Message -----
Sent: Monday, February 03, 2003 10:20
AM
Subject: Personal Representatives
In the Privacy Regulation, reference is made to
Personal Representatives being able to “act on behalf of an individual.”
For the right to request confidential communication, are covered entities
providing an address and phone number for the Personal Representative or
maintaining for the individual only?
Thanks!
Greg
Greg Bard
NASCO
HIPAA Privacy and Security Project
Manager
(W) 678.441.6059
(F) 678.441.6359
[EMAIL PROTECTED]
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