Updated: Jul 23, 2020
The HIPAA Privacy Rule permits HIPAA Covered Healthcare Providers to use Protected Health Information (PHI) to identify and contact their former patients who have recovered from COVID-19 and instruct them on how to donate their blood and plasma (Convalescent plasma), as it contains antibodies that can help treat other patients diagnosed with COVID-19.
Such use of those patients’ Protected Health Information (PHI) for such specific purposes is permitted as a population-based healthcare operations activity of the Covered Healthcare Providers: The facilitation of the supply of donated blood and plasma will improve their ability to conduct case management for patients’ populations susceptible to infection of COVID-19.
Patients’ signed authorization is not required as long as such activity is not for marketing purposes.
The Minimum Necessary Rule applies, as such specific use or disclosure is for healthcare operations.
To read more, check out the guidance at: