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HIPAA: Accounting of Disclosures

OHSU is required to keep an accounting of certain disclosures of health information. A disclosure is a release of information outside of OHSU. In general, OHSU is required to keep a history of when and to whom protected health information (PHI) is disclosed if the disclosure occurs outside the scope of treatment, payment and health care operations, and is not made as a result of a signed authorization from the patient. Examples of disclosures that may be included in the accounting requirement are public health activities (reporting immunizations, birth and death certificates, cancer/tumor registries, pregnancy terminations), reports about victims of abuse, neglect, or domestic violence, information used for organ or tissue donation and transplantation, disclosures about decedents to coroners, medical examiners, or funeral directors, and other disclosures required by law. For each disclosure the following shall be recorded: the date of the disclosure; the name and, if known, the address of the recipient of the health information; the type of health information disclosed; and the purpose of the disclosure.

An individual has a right to receive an accounting of disclosures of PHI made by OHSU beginning April 14, 2003. Patients are entitled to one free accounting within a 12-month period.

OHSU disclosures that are subject to the accounting requirement shall be recorded in the Accounting of Disclosures System (ADS).

  • Disclosure Guidance Document
  • Frequently Asked Questions About the Accounting of Disclosures Requirement
  • OHSU Accounting of Disclosures System (ADS) Summary
  • ADS Worksheet
  • ADS User Training Online (Ozone)
  • Request Form for the Temporary Suspension of an Individual's Accounting


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    Revised : November 3, 2003
    Web manager : oips@ohsu.edu