Community Grievance Decision Digest
RECORDS, CONFIDENTIALITY OF TREATMENT
The Laws
DECISIONS
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A hospital had a release of information allowing them to
share information about the patient’s care with her family.
However, they released records to the family that the patient
did not want released. The hospital acknowledged they had
exceeded the scope of the release of information they had and implemented
a procedure to ensure that this error did not occur again. Nothing
can undo the error, but the hospital’s actions were the
proper remedy under the circumstances. That is all the grievance
process can do. The patient could still take the hospital to court
if she wished. This matter was considered resolved. (Level III
decision in Case No. 97-SGE-01 on 5/27/97)
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Subsection 51.30(4)(b)5 allows access without consent
"...to qualified staff members of the department... as is
necessary to determine progress and adequacy of treatment..."
Thus the State Grievance Examiner is allowed to obtain
otherwise confidential records without the informed consent of the
complainant. (Level IV decision in Case No. 98-SGE-02 on 1/22/99.)
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A methadone clinic involved 17 different staff members
in a multi-disciplinary team meeting to discuss a patient’s
alleged dose-splitting. This team meeting included staff who
had no involvement with the patient and had no "need to
know" the treatment information about this client. The
patient provided no release of information. This process violated
the patient’s right to confidentiality of his treatment
information. (Level III decision in Case No. 99-SGE-02 on 5/17/00.
Appeal to Level IV by the patient was dismissed since the Level III
decision was in his favor.)
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A patient claimed a breach of confidentiality by her
therapist in a phone conversation with her mother. It was found that
the mother initiated the call because of her concerns
for her daughter and that the therapist was careful not to
divulge any information about the daughter’s treatment. The
mother asked the therapist not to tell the daughter about the phone
call. The therapist could not promise that she would not divulge that
the mother called, but eventually decided not to inform the daughter.
Her reasons for making that decision were documented. No breach
of the daughter’s confidentiality was found. (Level III
decision in Case No. 00-SGE-02 on 6/17/00, upheld at Level IV.)
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A client received services from an agency contracted by the county.
He felt that the provider releasing information, without his
consent, to an evaluator who was completing a vocational
assessment violated his confidentiality. The evaluator was from
a local university who had no official connection to the county’s
service delivery system. However, by mutual agreement all the parties,
including the client, he was to do a comprehensive vocational
evaluation the client. At a later meeting with the parties, the client
found out that county staff had shared specific information about his
mental health history but had not obtained a release from him to do
so. Other "consents to disclose confidential information"
were on file, but there was no release of information relative
to the staff’s involvement in the evaluation process. Was the verbal
sharing of any information with the evaluator was permissible? Any
information about the client’s mental health history and treatment
would constitute "treatment record" information within the
meaning of confidentiality laws. But the staff’s very presence at
the meeting was an identification of sorts that the client was
receiving services from the county. Did the presence of the staff at
the meeting and the client’s lack of objection at the time to any
information shared provide an implied consent on his part? Was any
information shared covered by some other exception to the requirement
for an informed written consent? It was concluded that this evaluation
was akin to a "second consultation" and not provided as a
routine "purchase of service" resource for county staff.
Thus, it did not readily fit into one of the exceptions to the
confidentiality law wherein there would is a pre-existing purchase of
services contract between the county and a provider. Further, the
section of HFS 94 that addresses a "second consultation"
notes that the person doing the consultation can review the client’s
treatment record. By the staff member’s un-objected-to presence,
the client may have provided an implied consent, but that this
was a "close call" in terms of the technical
confidentiality requirements. Since the vocational evaluation was set
up by mutual agreement of all parties, there likely was an expectation
of open sharing of treatment information to assist the evaluation
process. Nonetheless, it would have been best practice for the
service providers to have a clearly written release of information
from the client that would specify who all could be part of the
information sharing process. There was insufficient evidence to find a
rights violation. When outside evaluations occur, there should
be clear documentation of the evaluator’s legal status in
terms of that person’s right to access treatment information. For
example, is it being done under a purchase of services agreement, as a
second opinion/ consultation, or via a specific release of information
that clarifies who can provide treatment information, and what type,
to the evaluator. (Level III decision in Case No. 00-SGE-01 on
6/29/01.)
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Generally, information from a patient’s treatment records cannot
be released without the client’s written informed consent.
But there are exceptions to confidentiality laws allowing for
release of information without a patient’s consent. One such
exception stems from a 1988 Wisconsin Supreme Court decision in the Schuster
case. In that case, the Wisconsin Supreme Court said that mental
health therapists had a "duty to warn" any person who
may be the specific target of a threat of harm. The patient was angry
with a particular person and expressed that anger to his therapist. He
did not think that he had specifically threatened to harm that person.
However, if anger is expressed in a way that is assessed as
threatening toward another person, there is little choice on the part
of a mental health therapist but to share that information with a
person who may be the target of potential harm. In this situation the threat
was passed on, but no other treatment information was shared.
That disclosure was not a violation of the client’s
right to confidentiality of his records. (Level III decision in Case
No. 00-SGE-12 on 8/6/01.)
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A patient, who had complained about her therapist and physician,
expressed concerns about the confidentiality of her involvement
in the grievance procedure and any follow-through that had
occurred with her provider. She alleged that the entire staff of the
service provider knew about her complaints. The director of the
service provider noted that the record keeping system for grievances
was entirely separate and that only staff with a "need
to know" are given access to or information about the
filing of grievances. Only a select group of management and treatment
staff were aware of this patient’s grievances and information about
them was not available to others. It was found that the confidentiality
of this grievance was honored and no rights violation occurred.
(Level III decision in Case No. 00-SGE-03 on 9/12/01.)
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A patient wanted to bring a friend to her therapy sessions.
The service provider agreed that there are times that it may be
appropriate, especially if the person is a primary support person for
the client. Bringing another person to a therapy session requires a
signed release from the patient. Since the requested remedy was
provided, this issue was considered resolved. (Level III decision in
Case No. 00-SGE-03 on 9/12/01.)
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A patient complained that his therapist allegedly asked
him if his wife was having an affair. He responded that he
would kill her and her boyfriend. He also threatened to kill the
therapist. The therapist discussed this with her supervisor and was
instructed that she had a duty to warn the wife of the threat.
The therapist informed the wife and the police. When the police
questioned the husband, he threatened to harm them, too. These threats
led to his emergency detention. The therapist’s actions were
appropriate under the circumstances. She did have a duty to warn
where threats were made about immediate harm to specific people.
(Level III decision in Case No. 01-SGE-06 on 10/18/01.)
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A service recipient asked a temporary receptionist for a
grievance form. The temp asked other staff where the complaint
forms were. The case manager heard about the request and asked the
individual to come to her office to discuss her concerns. The
grievance she wanted to file, however, was about her case manager.
There was no evidence that anyone tried to talk her out of filing a
complaint, nor any indication of reprisal, retaliation or
discrimination because of her grievance. There was no violation of her
right to file a complaint. The temp asking other staff where
the grievance forms were did not violate her right to
confidentiality. (Level III decision in Case No. 01-SGE-05 on
11/29/01.)
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Last Updated: November 07, 2006 |