Posted by Diane on 9/14/08

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I am the manager of a medical spa in California. We leased
out a room to an esthetician for one year. She had access
to our patient software program to schedule appointments.
She did perform treatments on approximately 30 patients.

In May, she decided to open her own spa down the street.
I discussed with her our confidentiality agreement and
reminded her under HIPAA guidelines, she must not remove
any patient information without the patient's consent.

We adhere to strict HIPAA guidelines. Every patient signs
the an agreement and is aware of their confidentiality
rights.

I have just received complaints from several patients
forwarding an email they received from this esthetician
without verbal or written consent. This email is
advertising her new location and services.

Is she out of compliance with regards to patients she has
not treated?

Thank you.
Diane

Re: HIPAA VIOLATION?, 9/14/08, by Diane.

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