Information systems activity review is a fancy way of saying you need to monitor your network and your applications including who is looking at and manipulating your patient information. That can be an expensive, or even almost impossible, proposition when it comes to regular monitoring of access to patient information stored in electronic health records (EHR). Two of the well-known automated audit logging tools on the market, FairWarning and Iatric, are well outside the budget for small- to medium-sized covered entities (CE). The manual option, checking audit logs by hand, is slow and ineffective.
Q: Is it permissible to take pictures of patients for identification purposes as a part of the registration process? Do the patients need to sign a consent form before their picture can be taken?
A: It is permissible to take pictures of patients for identification purposes if the patient agrees to it. Since the Privacy Rule considers full-face photographs to be a patient identifier, it is a good practice to get the patient's written consent to take a photograph and file it with the patient's electronic record. The patient should be allowed to opt out of the photograph if he or she chooses.
Editor's note
Brandt is a healthcare consultant specializing in healthcare regulatory compliance and operations improvement. She is also an advisory board member for BOH. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions. Opinions expressed are those of the author and do not represent HCPro or ACDIS. Email your HIPAA questions to Associate Editor Nicole Votta at nvotta@hcpro.com.
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