Request for Alternative Means or Location for Confidential Communications for Protected Health Information (PHI)

Title

The University of North Carolina at Chapel Hill Policy on Requesting Alternative Means or Location for Confidential Communications for Protected Health Information (PHI)

Policy

Pursuant to the Health Insurance Portability and Accountability Act of 1996, as modified by the Health Information Technology for Economic and Clinical Health Act of 2009 ("HIPAA"), individuals have the right to request reasonable alternative means of communications from health care providers in order to ensure confidentiality. If alternative means of communications are not requested, the health care provider will freely communicate with the individual through the standard means of telephone and/or post to the telephone number(s) and address(es) provided by the individual. It is important to ensure that individuals can receive communications regarding their protected health information ("PHI") in a means and location that the individual feels is safe from unauthorized use or disclosure. The University of North Carolina at Chapel Hill ("UNC-Chapel Hill") will accommodate reasonable requests by individuals to receive communications of PHI from the UNC-Chapel Hill Covered Components by alternative means or at alternative locations.

Procedure

1. Individuals must request alternative means of confidential communications in writing, using the form Request for Confidential Communications. Reasonable requests include (but are not limited to) using alternative telephone numbers, alternative addresses, refraining from leaving messages on answering machines, and refraining from mailing information to the individual. Unreasonable requests are those that would be too difficult technologically or practically for the Covered Component to accommodate.
2. Covered Components will not require any explanation from the individual of the reason for the request as a condition of providing alternative communications on a confidential basis.
3. When appropriate, Covered Components may condition the provision of a reasonable accommodation on information as to how payment, if any, will be handled, and specification of an alternative address or other method of contact. For alternative billing communications, an alternative means or location that is satisfactory to both parties will be designated on a case-by-case basis before communication of PHI is made.
4. If the Covered Component determines that a request is unreasonable, the University's Chief Privacy Officer, or his/her designee representative at the Covered Component, will work with the individual to attempt to come to a solution acceptable to both parties. In the event that the request is unreasonable and cannot be accommodated, the Covered Component will inform the individual in writing.
5. Authorized Covered Component personnel will be responsible for noting the alternative means of communication, so that it can be communicated to anyone needing to send health or billing information to the individual. All requests for alternative means of communication or alternative locations will be maintained in the individual's medical record maintained by the Covered Component.
6. Knowledge of a violation or potential violation of this Policy must be reported directly to the University's Chief Privacy Officer at (919) 962-6332 or attn.: University's Chief Privacy Officer, UNC-Chapel Hill, Institutional Privacy Office, 103 Airport Dr., Ste. 106, Chapel Hill, NC 27599 CB# 1025