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CHALLENGES TO PATIENT CONFIDENTIALITY Potential Breaches Outside the Health Center INSURANCE Implementation of the ACA in conjunction with Medicaid expansion has increased the number of individuals covered by Medicaid or commercial health plans, expanding access to care in many states. However, billing these third party payers can result in the generation of explanation of benefits (EOBs) and other communications to the policyholder that can potentially compromise confidentiality for covered dependents. $$$ CONFIDENTIAL ? ! ? Health information for dependents may be sent to the policyholder through • EOBs and claims • Bills • Patient Portals • Deductible information Children Young adults Spouses and Policyholder (18–26) domestic partners LAB/PHARMACY Labs and pharmacies are not always bound by the same confidentiality considerations as the health centers themselves and sending lab specimens and prescriptions to these entities risks the generation of an EOB or a bill. Some health centers may mail lab results to a patient if, after two efforts within 48 hours to reach the patient by telephone, they are unable to be reached. Having prescriptions sent home through an online pharmacy benefit, for example, could be risky for someone whose partner might sabotage their birth control. Some pharmacies have begun sending “noncompliant notices” in cases where clients do not pick up their prescriptions, and that could jeopardize client confidentiality. !
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