Verification Requirements

• Verification Tips

Prior to any disclosures (except for disclosures where a patient may agree or object), we must: 

• Verify the identity and authority of a person requesting protected health information (PHI) if the identity of the person is not known, and
• Obtain any documentation, statements, or representations (whether oral or written) from the person requesting the PHI when such documentation, statement, or representation is a condition of the Rule.

Identity of public officials

When disclosing PHI to a public official, reasonable reliance can be applied if you determine that such reliance is reasonable under the circumstances based on any of the following:

• If the request is made in person,presentation of an agency identification badge, other official credentials, or other proof of government status
• If the request is in writing, the request is on the appropriate government letterhead
• If the disclosure is to a person acting on behalf of a public official, a written statement on appropriate government letterhead that the person is acting under the government's authority or other evidence or documentation of agency (such as, a contract for services, memorandum of understanding, or purchase order) that establishes that the person is acting on behalf of the public official.

Whenever possible, forward requests for PHI from public officials to the Health Information Management (HIM) Department to ensure the proper application of verification procedures as well as for logging and tracking as required under the Accounting of Disclosures section of the Privacy Rule.

Authority of public official

We can rely, if such reliance is reasonable under the circumstances, on any of the following to verify authority when the disclosure of PHI is to a public official or a person acting on behalf of the public official:

• A written statement of the legal authority under which the information is requested, or
• If a written statement would be impracticable, an oral statement of such legal authority
• A badge or business card is also acceptable;

If a request is made pursuant to legal process, warrant, subpoena, order, or other legal process issued by a grand jury or a judicial or administrative tribunal, it is presumed to constitute legal authority.

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