Food Banks as Partners in Health Promotion: Navigating HIPAA

Authors
Jarrod Nelson, Sarah Downer, Rachel Landauer, Morgan Smith
Implementation Tool
June 2020
View the resource

Headline

Food banks can use this tool to learn approaches to information-sharing for health care partnerships and interventions.

Background

Food banks nationwide often collaborate with local health care providers and payers to better ensure patients have access to nutritious foods. These partnerships may involve sharing patient data, which is legally protected under the Health Insurance Portability and Accountability Act (HIPAA) for providers and payers, as they are considered covered entities. This guide provides food banks with advice on navigating HIPAA requirements when forming health care partnerships.

About this Tool

This guide outlines the history and key concepts of HIPAA, including definitions of protected health information and covered entities. It also outlines four approaches for food banks to share health information in a way that complies with HIPAA regulations:

  1. Patient Driven Information Sharing: When authorizations are obtained from the patient to share health information between food banks and providers or payers;
  2. Disclosures for Treatment Purposes: When health information can be shared with providers to further a patient’s treatment and care;
  3. Business Associate Arrangements: When health information is shared for case management or population health purposes; and
  4. Research and Program Evaluation Arrangement: When limited health information is shared for in support of research and program evaluation activities using data use agreements.

The guide also includes examples of food bank-health care partnerships involving information sharing, templates (patient authorization to disclose health information, partnership agreement, data use agreement), and answers to common questions related to covered entities and HIPAA compliance.

Policy/Program Takeaways

Food banks and their health care partners can use this guide to ensure health-related information sharing complies with HIPAA where applicable.

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