At this week's Safeguarding Health Information conference, the HHS Office for Civil Rights again confirmed that a proposed rule will be issued that will govern accounting for disclosures even for payment, treatment and health plan operations.

Individuals will be able to demand that covered entities not transmit information to health plans regarding treatment paid for out-of-pocket. And it will require that patients have greatly expanded access to disclosure information. Tell me, is this laying it on a bit heavy? Do you have the processes and technological infrastructure in place to segment and parse out disclosure data according to patients' directives?

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