Question
As you continue to explore fundraisingactivities under 45 C.F.R. 164.514(f), I wanted to direct your attention to the following helpful guidance distributed by the Association
As you continue to explore fundraisingactivities under 45 C.F.R. 164.514(f), I wanted to direct your attention to the following helpful guidance distributed by the Association of American Medical Colleges (AAMC):
https://www.aamc.org/system/files/c/3/376966-hipaa_advisory.pdf
Please take some time to review the AAMC guidance. As you will note, it provides a helpful Q&A with regard to the scope of some aspects of fundraising in the context of HIPAA. Let's focus on the section in which AAMC notes that the following areas of PHI may require extra protection under state and/or federal regulations:
"Special consideration should be contemplated for the following; Mental Health, Psychotherapy Notes, Substance Abuse Communicable Diseases, sexually transmitted infections, HIV/AIDS Genetic Testing Infertility treatment Abuse, including pediatric, adult with disability, elder abuse, sexual assault Other applicable state provisions." Id. at #6.
Assume that you are the Director of Fundraisingat the Hilltop Hospital. You have been asked to spearhead an aggressive fundraisingcampaign targeting development of both the mental health and substance abuse divisions within the hospital. You have been asked to target raising $10 million in donations. You are meeting with your team to strategizeas to the permitted scope of fundraisingactivities under HIPAA, as well as any other relevant federal statutes, with regard to patients who have been treated by either the mental health or substance abuse division of the hospital. Please describe your recommendations in that regard, noting any relevant statutes/regulations that support your recommenda
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