Does depositing credit card payments and checks create HIPAA risk?

Does depositing credit card payments and checks create HIPAA risk?

One of the blogs monitored by mhconcierge.com, Person-Centered Tech, asks an interesting question: when we deposit a check or credit card payment from a patient/client, isn’t this creating a record that they have received a mental health service. In other words, does this create a version of personal health information (PHI), a category of data which is protected by this?

The blogger, Roy Huggins, who seems highly knowledgeable about these sorts of issues, has bad news and good news, mostly good news, for us about this question. It is his understanding that making a deposit does indeed create a record of a service provided, and this is a form of PHI. On the other hand, it is his understanding that banks have a special standing under HIPAA, which allows us to get paid, and there’s no problem with these types of payments.  See his online article, which is an update of a previous article, for more details.

mhconcierge’s take: is a good thing that somebody who is knowledgeable is asking the sorts of questions, and able to provide knowledgeable and well-researched answers.  Thanks for Roy for providing his high quality website and blog. 

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