Podiatry Coding & Billing Alert

Reader Questions:

Gauge PHI Risk With Patients’ Names

Question: Is it OK to call out full names in a waiting room? Can you ask for “John Smith,” or should you only ask for “John”? We’ve been using full names, but our new office manager says that’s not allowed.

Wisconsin Subscriber

Answer: Calling out patient names in a covered entity’s office or facility is covered under the incidental uses and disclosures rule. And in order for your incidental disclosures to be OK, you’ve got to apply the safeguarding requirements and the minimum necessary requirements.

Therefore, an entity needs to ask the following: What is the minimum necessary amount of information that you need to call out?

If you just call “John,” how many people are going to come to the front? Perhaps simply calling “John S.” would be an application of the minimum necessary rule that would be reasonable for your waiting room or office. On the other hand, if you stand up there and call “John S.” and nobody responds and you think maybe people just aren’t hearing their name, then it might be perfectly reasonable to go ahead and use the full name to get somebody’s attention in a busy waiting room. Use your judgment in determining the minimum required and consult an attorney if necessary.


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