Accounting For Disclosures and UCMC DisclosureTrac

HIPAA requires UCMC to keep track of the times patient information is disclosed under certain circumstances.  This is called an "Accounting for Disclosures."  Patient authorization is not needed to disclose a patient's information in these circumstances, and patients have a right to ask UCMC for this list of disclosures.

What type of disclosures does UCMC need to track?  Some examples of the types of disclosure UCMC needs to track are:  reports of abuse and neglect, communicable disease exposure notification, FDA reporting, and erroneous disclosure (e.g. misdirected fax).  A complete Accounting for Disclosures chart from the HIPAA Program Office can be found here. 

Tracking Disclosures.  To make Accounting for Disclosures easier, UCMC has a centralized electronic system to log disclosures called DisclosureTrac.  The DisclosureTrac software and various forms (including a System Access Request Form to request access) can be found at http://home.uchospitals.edu.  (Select the Tab: Clinical --> Compliance --> Disclosure Tracking)

Exemptions.  Certain disclosures are exempt from the Accounting for Disclosures requirement.  Disclosures for the purposes of treatment, payment or health care operations, disclosures to the patient about his/her own health information, and disclosures after UCMC obtains a signed authorization are all exempt from the Accounting for Disclosures requirement.

Contact the HIPAA Program Office (HPO) at 4-9716 or HPO@bsd.uchicago.edu for more information.