On May 31, HHS Published a notice of proposed rulemaking (NPRM) on the HIPAA Privacy Rule Accounting of Disclosures Under the Health Information Technology for Economic and Clinical Health Act (HITECH).
The post in the link above does a good job of summarizing some of the complexity surrounding the proposed NPRM regarding accounting disclosures. Dr. Halamka makes the point that for large covered entities this may be quite a burdensome requirement to meet.
I would suggest that this holds true for covered entities of all sizes and will be nearly impossible to do without best of breed HIPAA Compliance Software. Fortunately, there are now SaaS based affordable options even for the little guys.
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