The question is posed: what about sign-in sheets, where folks knowingly and
willingly offer up their personal information?
Well, it depends upon whether you are a "covered entity." And that is most
of us (well, in the USA).
If you are a "covered entity" falling under HIPAA, you must comply with
*all* of HIPAA, incl. its privacy sections. "Incidental information" may be
displayed for the entire world to see (i.e. patient name, and arrival time,
on the waiting room list). However, just about anything other than that
must be shielded from curious eyes (like reason-for-visit, or due date, or
address, or e-mail, or all the bits of information that make a sign-in sheet
useful).
Now, I can envision this scenario: you lead a class, and obtain "collective
verbal consent" from all the students present ("Do y'all mind if I pass
around the sign-in sheet, where you will share -- and see -- your personal
information?") Clever, huh?
NOT SO FAST. Remember: once you are under HIPAA, you are under *all* of it
.... and that includes requirement for prior written consent to the
disclosure of private information. By the time you get everyone to sign one
a form indicating that they don't give a hoot if their classmates see their
address and due date, they will have lost any urge to fill out the sign-in
sheet itself.
I think I should stop *posting* about HIPAA, pull all of this into a
presentation proposal for ILCA 2004 like I keep telling myself I should, and
then become a millionaire by creating and *selling* lactation-specific HIPAA
manuals and forms. Bill Gates -- look out!
Liz Brooks, JD, IBCLC
Wyndmoor, PA, USA
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