The Real Talk article series includes real customer questions and our answers. Since these are questions directly from actual clinics, practices, hospitals, and businesses, we thought you might have these questions too. We hope that you find this format helpful. Stay tuned for more Real Talk - your question might even be featured!
Question: I was wondering what patient identifiers we can use when calling patients from the waiting room to bring them back to the treatment room without violating HIPAA. We usually and have always used the first name of the patient only but we recently encountered a few situations were we had more than patient with the same first name around the same time slot. I was wondering if we could use the patients’ first and last name when calling them back.
Answer:
In short, using a patient's full name in the context of calling them into treatment from a waiting room is considered acceptable under HIPAA.
Why?
HIPAA permits disclosure of a patient's protected health information (identifying information like their name is considered PHI) in the course of treatment, payment, or healthcare operations without their prior authorization.
Given that other patients overhearing a name being called is an "incidental disclosure" that cannot be avoided since it's a common waiting area and it is in the course of patient treatment, this is permitted.
The other consideration here is what's called the minimum necessary principle which states that you must use the minimum necessary amount of information possible to satisfy the task at hand. In this case, you may consider using first name, then first name and last initial, and if that isn't specific enough, then full name. At each instance, you're attempting to use the minimum necessary information to call the patient back for treatment.