Management Services Organization Refines Privacy Strategy

A management services organization that provides services to affiliated but independent clinics came to Faegre Drinker for legal counsel related to its privacy strategy, among other matters. The organization maintains a single instance of an electronic health record used by all affiliates, and because the architecture of the record is relatively open, Faegre Drinker worked to determine the technological, contract and policy means to protect data elements within the health record from view by affiliates without a need to know, as well as third parties. Because the clinics provide reproductive health care services, among others, and as various states enact restrictive laws, including some with criminal penalties, it is increasingly important that information about care provided not be accessed by anyone other than those with a clinical reason to know.