USCG guide: HIPAA compliance in health care

The United States Coast Guard has issued Commandant Instruction COMDTINST 6000.8 that implements the policy for compliance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule in CG Health Care Programs.

It establishes regulations governing the handling and dissemination of protected health information (PHI) within the Coast Guard. Here are some key takeaways:

All Coast Guard personnel, including health care providers and plans involved in electronic standard transactions, are subject to the HIPAA Privacy Rule.
Permissible uses and disclosures of PHI encompass treatment, payment, health care operations, public health endeavors, law enforcement activities, and specialized government functions.
Certain circumstances mandate a valid authorization for PHI use or disclosure.
The document delineates the roles and duties of the CG HIPAA Privacy Officer (CGHPO) and the CG HIPAA Security Officer (CGHSO).
It permits the utilization and sharing of PHI for military personnel when deemed necessary by the appropriate military command.
Adherence to the minimum necessary rule ensures that only the requisite amount of PHI is utilized or disclosed.
CG clinics are obligated to furnish beneficiaries with a Notice of Privacy Practices (NoPP) and procure a signed acknowledgment.
Patients possess the right to review and obtain copies of their PHI, with some exceptions.
Beneficiaries retain the option to lodge complaints concerning the misuse or disclosure of their PHI.
Breach pertains to the unauthorized acquisition, access, use, or disclosure of PHI compromising its security or privacy.
CG clinics must maintain a record of PHI disclosures and furnish an account upon request.
HIPAA training is mandatory for all CG health care staff.
Business associate agreements (BAA) are necessary to safeguard PHI.
The Military Command Exception permits the disclosure of PHI to authorized military command entities.
Healthcare providers are obligated to inform commanders under specific circumstances, such as potential harm to self or others, mission-related harm, or inpatient care.
Commanders are responsible for safeguarding the privacy of provided information and diminishing stigma surrounding seeking mental health support.

This Commandant Instruction was published on 30 April 2024.

For more information, please see the document below (available only to subscribers):