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Law Educator, Esq.
Law Educator, Esq., Attorney
Category: Legal
Satisfied Customers: 118257
Experience:  JA Mentor -Attorney Labor/employment, corporate, sports law, admiralty/maritime and civil rights law
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Chiricahua Community Health Centers, Inc is in the process

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Chiricahua Community Health Centers, Inc is in the process of hiring a Providers located about 4 hours away from or main location to conduct Peer Review on one of our Providers (Internal Medicine) other provider is also Internal Medicine. Due to the distance, our current plan will be to print out copies of the records and labs then faxing these items to them. We will also be blanking out the names, DOB etc of the patients.

In establishing the contract for the peer review and Business Associate Agreement, should we add into this proper destruction of the records and verification they have been destroyed?

Or blanking out all PHI and indicator this would be over kill?
Thank you for your question. I look forward to working with you to provide you the information you are seeking.

Under HIPAA, while you can hire a review and can share PHI for this purpose, your contract with the Providers providing the review must specify they agree to and understand they are bound under HIPAA with the information. In addition, you should add that they are to comply with HIPAA regulations regarding destruction of the records and will provide you verification they have disposed of the records in accordance with all HIPAA guidelines.

This is not overkill even though you are blocking out identifying information, because sometimes in these records things get missed and some information may be buried in the records themselves that could identify the patients.

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