What is an accounting of disclosures of Protected Health Information?

An accounting of disclosures of Protected Health Information (PHI) refers to a record maintained by covered entities under HIPAA regulations, detailing instances where a patient’s PHI has been shared with external parties, excluding those disclosures made for treatment, payment, healthcare operations, disclosures authorized by the patient, and certain other exceptions, providing patients with transparency regarding who has accessed their PHI and for what purpose. The purpose of this accounting mechanism is to ensure patient privacy and data security. Documenting instances where PHI has been shared with external entities promotes transparency and accountability in healthcare practices.

An accounting of disclosures provides a detailed inventory of instances where a patient’s PHI has been disseminated to parties outside the scope of the covered entity. This inventory covers a range of scenarios, including but not limited to, disclosures made for purposes other than treatment, payment, and routine healthcare operations. These disclosures could involve sharing PHI with external entities such as insurance companies, regulatory bodies, law enforcement agencies, research institutions, or other healthcare providers. This accounting covers intentional disclosures as well as inadvertent or unauthorized releases of PHI, encapsulating a variety of data-sharing events.

The need for maintaining such records arises from the principles of patient privacy and confidentiality required by HIPAA. By documenting the dissemination of PHI, healthcare organizations fulfill their obligation to provide patients with insight into who has accessed their sensitive health information and for what purpose. This transparency promotes trust between patients and healthcare providers and also empowers individuals to exercise greater control over their health data. An accounting of disclosures also serves as a mechanism for regulatory compliance and risk mitigation within the healthcare industry. HIPAA requires covered entities to maintain accurate and up-to-date records of PHI disclosures, allowing for audits and investigations to ensure adherence to privacy regulations. By documenting each disclosure event, healthcare organizations can demonstrate compliance with HIPAA requirements and mitigate the risk of potential data breaches or privacy violations. In the event of an audit or investigation, these records serve as invaluable evidence of data stewardship and regulatory adherence.

The process of generating and maintaining an accounting of disclosures involves several key steps, each necessary for ensuring accuracy, completeness, and compliance with HIPAA regulations. Initially, covered entities must establish policies and procedures governing the documentation of PHI disclosures, outlining the requirements for recording such events and the individuals responsible for maintaining the records. These policies should align with HIPAA guidelines and consider the unique operational context of the healthcare organization. Then, healthcare professionals must diligently record each instance of PHI disclosure in a centralized and secure database or system designated for this purpose. This database should capture pertinent details regarding the disclosure event, including the date and time of the disclosure, the identity of the recipient(s) of the PHI, the purpose of the disclosure, and any relevant contextual information. Healthcare professionals should document any exceptions or permissible disclosures exempted from accounting requirements under HIPAA, ensuring accurate record-keeping.

Throughout this process, strict adherence to data security protocols is important to safeguarding the confidentiality and integrity of PHI. Covered entities must implement encryption, access controls, and authentication measures to prevent unauthorized access to the accounting of disclosures database. Regular audits and quality assurance checks should be conducted to validate the accuracy and completeness of the records and identify any discrepancies or anomalies that may require remediation.

Besides maintaining records of PHI disclosures, covered entities have a corresponding obligation to provide patients with access to their accounting of disclosures upon request. HIPAA gives individuals the right to obtain a detailed report of who has accessed their PHI and for what purpose, allowing them to monitor and manage the dissemination of their sensitive health information. Healthcare organizations must establish procedures for fulfilling such requests in a timely and efficient manner, ensuring compliance with HIPAA’s patient access provisions.


An accounting of disclosures of Protected Health Information constitutes an important mechanism for promoting transparency, accountability, and regulatory compliance within the healthcare industry. By documenting instances of PHI dissemination, healthcare organizations follow the principles of patient privacy and confidentiality while mitigating the risk of data breaches or privacy violations. Through diligent record-keeping, adherence to data security protocols, and patient engagement, healthcare professionals can ensure the integrity and trustworthiness of their accounting of disclosure processes, advancing the goals of HIPAA and safeguarding patient privacy in the healthcare industry.