Treatment, Payment & Healthcare Operations

May I use or disclose PHI for treatment, payment or health care operations?

Yes. A health care provider may use or disclose protected health information (PHI) for treatment, payment or health care operation (TPO) or internal purposes within the Organized Health Care Arrangement (OHCA) without obtaining patient authorization. If your authorized role or job function includes provision of care or treatment to patients then you may obtain the information you need to help you care for your patients. Minimum Necessary is always a good rule of thumb to follow to be mindful of the patient's privacy, confidentiality.

Use

The term "Use" refers to how we share PHI within the OHCA. Before "using" someone's PHI, ask the following questions:

1. Am I sharing PHI within the OHCA for treatment purposes?
2. Am I sharing PHI within the OHCA for payment purposes?
3. Am I sharing PHI within the OHCA for healthcare operations?

If the answer to these questions is yes, you do not need patient authorization. If the answer to these questions is no, patient authorization is required.

Disclosure

The term "disclose" or "disclosure" refers to how we share PHI outside of the OHCA. Disclosure means the release, transfer, provision of, access to, or divulging in any other manner of information outside the entity holding the information. Follow the guidelines under uses and disclosures outside the OHCA and general authorization guidelines under the Authorization Requirements sections.

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