[ RadSafe ] Dosimetry Reports

[Madson, Daniel P.]

Joe,

Here is a link to a good article on the subject:
http://www.mcw.edu/FileLibrary/Groups/AMRSO/Files/watercooler/HIPAA.pdf.

To quote from the article: The Rad Safety Department is "... NOT deemed
a 'covered entity' per definition of the regs since they
do not seek nor receive reimbursement from a health insurance company
related to the dose monitoring of employees. Hence, they are NOT bound
by the HIPAA regulations."

Hope this helps.

Dan Madson
SAIC

Are OSL dosimetry reports showing personnel doses to individuals, whose
names are listed on the report, subject to the privacy provisions of
HIPAA (the Health Insurance Portability and Accountability Act)?  The
personnel director for one of my clients has determined this to be the
case.  In some facilities I have visited recently, the dosimetry reports
are posted on the bulletin board in the break room or near the NRC Form
3 Notice to Workers for all to see.  She treats bioassay reports the
same way.  I don't have an opinion either way, as I can see merit in her
analysis.  But, this is a new one to me.

Any comments or advice?