Page 79 - Privacy_Program

DISCLOSING PHI FOR FUNDRAISING PURPOSES [DP166]
Back to Table of Contents

Scope: Enterprise
Distribution: Executive Leadership Team; Director of Information Technology, Privacy and Data Security; All Employees with
Access to Protected Health Information (includes Contractors, temporary employees and Interns)
Purpose: To clarify when the organization may disclose Protected Health Information for fundraising purposes.
External Regulation or Standard: 45 C.F.R. §164.514(f) ‐ uses and disclosures for fundraising

Who is Statement Policy, Standard, or Procedure Statement
Responsible Number
Development and DP166.1 The organization may only disclose Protected Health Information (PHI) to a
Marketing Employees, business associate or affiliate for activities related to fundraising with an
and Others with Access authorization by the individual of such information, except in the following
to Protected Health situations:
Information (PHI)
DP166.1a (a) Using or disclosing demographic information relating to an individual to a
business associate or affiliate for raising funds for the organization’s own
benefit;
DP166.1b (b) Using or disclosing dates of health care provided to an individual to a
business associate or an affiliate for raising funds for the organization’ own
benefit.
Development and DP166.2 All fundraising materials that are sent to participants will include a description of
Marketing Employees, how the participant may opt out of receiving any further fundraising
Employees and others communications. The organization will make reasonable efforts to ensure that
with Access to PHI individuals who decide to opt out of receiving future fundraising communications
are not sent such communications.
Development and DP166.3 PHI will not be used to develop potential donor lists.
Marketing Employees,
Employees and others
with Access to PHI

GES CONFIDENTIAL 75