What are examples of patient data that behavioral health providers should and should not share with Connie?
The following are examples of what the official statewide HIE would be interested in collecting from behavioral health providers as part of care coordination, as well as examples of what should not be shared with Connie. All providers must check with their specific licensure regulations to determine specialized privacy rules beyond HIPAA, in accordance with the regulations governing their specific license, certification, and/or specialty.
HIE Data of Interest
- Patient List
- Symptoms and Diagnosis
- Summary of Treatment Plan
- Summary of Progress
- Prescribed Medications
- Discharge Summary
- Billing Information (e.g. CPT codes/insurance codes)
- Diagnosis Codes (e.g. CD10 codes)
- Any patient consented data that will help in the holistic care and treatment of the patient, alongside patient’s other providers.
Do Not Share
- Psychotherapy notes (HIPAA*)
- Therapist Observations
- Therapist questions for research
- Therapist thoughts about session
- Therapist hypotheses before diagnosis
- Court-sealed, non-treatment forensic services
- Federal or State legally protected data (e.g. FERPA, CGA Chapter 899, 42 CFR Part 2**)
- Event details or circumstances relating to symptoms, diagnosis, treatment, progress.
- Any information that requires patient consent under federal and state law, in which your patient/client does not consent to
*Behavioral health providers should not include “psychotherapy notes” a term under HIPAA meaning “notes recorded (in any medium) by a health care provider who is a mental health professional documenting or analyzing the contents of conversation during a private counseling session or group, joint, or family counseling session and that are separated from the rest of the individual’s medical record.” HIPAA excludes the following from the definition of “psychotherapy notes”: “medication prescription and monitoring, counseling session start and stop times, the modalities and frequencies of treatment furnished, results of clinical tests, and any summary of the following items: Diagnosis, functional status, the treatment plan, symptoms, prognosis, and progress to date.” 45 CFR § 164.501
**Certain health care provider specialists may be obliged to additional federal and state privacy laws that govern their specific license, such as substance use disorder (SUD) treatment known as 42 CFR Part 2, which requires affirmative consent from the patient before disclosure to, and through Connie.