Question

Raj has been reviewing copies of medical records of patients from his clinic to see if he can identify any opportunities for quality improvement. company policy requires raj to shred documents containing phi and to dispose of the shreds in locked bins for later disposal. but the door to the shredder room is locked and raj is tired. he decides to throw the copies out in the garbage can without shredding - just this once. has raj violated hipaa?

Answer 1

Throwing the copies out in the garage can without shredding because he’s tired shows Raj did not follow the company’s HIPAA P&Ps about proper disposal of PHI. He could have locked those copies for later "proper" disposal. Therefore, Yes! Raj has violated company policy and HIPAA.