As I read the proposed rule it didn't require any retention of the record, 
much less two years after the subject's death!  It simply proposed that the 
information contained in the record be kept confidential for two years after 
death.  Big difference, IMHO!

Gary Vocks
Records Management Officer
Southern Illinois University
School of Medicine
Springfield, Illinois  USA

----- Original Message ----- 
From: "Lisa Hawkins" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Thursday, November 02, 2006 2:42 PM
Subject: Re: [RM] HIPAA 2 Years?


> The two year limit was a proposal, documented here:
> http://www.hipaadvisory.com/regs/standardsprivacyindividid/applicationdecea
> sed.htm
>
> But that limit was NOT implemented as the regulation.  Follow the link at
> the top of the page I provided the link to and you can follow the LONG
> regulations for the actual law, Section 164.502(f) - Deceased Individuals
>
> Hope this helps.
> Lisa Hawkins
> Analyst - Information Policy, Compliance, and Archives
> Y-12 National Security Complex
> [log in to unmask]
> Phone: (865) 241-8166 - Fax: (865) 241-4566
>
> List archives at http://lists.ufl.edu/archives/recmgmt-l.html
> Contact [log in to unmask] for assistance
> 

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