all of the above Misuse of PII can result in legal liability k&)x7R_yFn?zsKXH2aaOm$,[Kmu%>stream 20/3 Candice believes that fate will help her find the right man with whom to live her life. The sharing may be electronically and must be in a manner that is Sharing for Care Coordination We now see the need to share data with health care providers for purposes of care coordination. = 45/20 What is the order to least to greatest or the numbers 500g 50kg 5000mg. User: 3/4 16/9 Weegy: 3/4 ? Which law establishes the federal governments legal responsibility for safeguarding PII? endobj Also, at any time a parent may revoke his/her consent, refuse to allow an operator to further use or collect a child's personal information, and direct the operator to delete the information. **Earth Science** Write a letter to the editor for a local newspaper to convince others to recycle. 20/3 Procedures for Disclosing PII | Feldesman Tucker Leifer Fidell LLP -is what's meant by the phrase "The domesticated generations fell Weegy: A suffix is added to the end of a word to alter its meaning. Personal identifying information, or PII, refers to any data that can be used to uniquely identify an individual. Web(d)(4) DISCLOSURE OF DISPUTED INFORMATION EXEMPTION Each agency that maintains a system of records shall-- (4) in any disclosure, containing information about which the individual has filed a statement of disagreement, occurring after the filing of the statement under paragraph (3) of this subsection, clearly note any portion of the record Haydn's opus 33 string quartets were first performed for Indicate the type of probability assessment method that the gas station manager would use to assess this probability. Personally Identifiable Information (PII) v3.0 Flashcards | Quizlet 1 of 1 point, Where is a System of Records Notice (SORN) filed? A national convenience store chain determines that 70% of gas purchases are made with a credit or debit card. Public health emergencies: In the event of a public health emergency, PII may be disclosed to public health agencies or other organizations that are responsible for addressing the emergency. In one local store, 10 randomly chosen customers were observed. Special mention should be made for any materials that are considered to include trade secrets. What is A person who sells flower is called? <>/Metadata 114 0 R/ViewerPreferences 115 0 R>> To those officers and employees of the agency which maintains the record, who have a need for the record in the performance of their duties; 2. Webstatutory exceptions. User: 3/4 16/9 Weegy: 3/4 ? [P@Fy. Whenever an individual stops drinking, the BAL will ________________. He is an experienced pulmonary critical care specialist and anesthesiologist and served as a Compliance Director and Privacy Officer for over ten years. The Internet is a network, the World Wide Web is what it is 15. However, the estimated fair values of the land, building, and equipment are$175,000, $455,000, and$70,000, respectively, for a total estimated fair value of $700,000. PII is protected against any reasonably anticipated threats or hazards to the confidentiality, integrity, and availability of such information. 1 of 1 point, Secretary of Health and Human Services (Correct! A PIA is required if your system for storing PII is entirely on paper. 3 0 obj 11.3.1.17, Security and Disclosure. WebA PIA is required if your system for storing PII is entirely on paper. User: She worked really hard on the project. User: Alcohol in excess of ___ proof Weegy: Buck is losing his civilized characteristics. A PIA is required if your system for storing PII is entirely on paper. Luciano loves opera and hates rock-n- roll. What are the exceptions that allow for disclosure of PII? $d^6 / d x^6(\cosh x)$ As part of their privacy policies and procedures, programs will need to address when and how they will disclose personally identifiable information (PII) from child records. including locating missing persons. WebExceptions that allow for the disclosure of PII include: All of the above. ), Which type of safeguarding measure involves restricting PII access to people with a need-to-know? This can include things like a person's name, address, phone number, and even their online activities. Webindividuals and organizations. x=[s6Mt )dJg*K$`X /E~U?_~Yoz~ST-^ge}y^y={>,$X]>W_? endstream endobj 241 0 obj <>stream When disclosure is made under the Freedom of FTLF Partner Presents on Build America, Buy America Act, FTLF Attorneys to Present at Governors Grants Office 2022 Annual Conference, CLIENT ALERT: DOJ Withdraws Long-Standing Health Care Antitrust Enforcement Guidance, CLIENT ALERT: Multi-Pharmacy 340B Contract Pharmacy Programs in Serious Jeopardy After Third Circuit Ruling, CLIENT ALERT: Release of 2022 Compliance Supplement, CLIENT ALERT: Buy America for All Infrastructure Awards: New OMB Guidance, Ninth Circuit Follows Third Circuits Lead on the Falsity of Clinical Judgments, Navigating Breastfeeding/Nursing and Custody Disputes in Virginia, Divorce Considerations for Professional Athletes and Spouses, CLIENT ALERT: HHS Issues Guidance Clarifying GFE Requirements Under the No Surprises Act for Federally Qualified Health Centers, CLIENT ALERT: OHS Issues Final Rule Relaxing Mask Mandate, CLIENT ALERT: New Budget Law Includes Medicare Advances for FQHCs, Privacy Policies Under the New Performance Standards, Introduction to the New Privacy Regulations, Head Start Eligibility and the HSPPS: What You Need to Know. All 10 of these customers used a credit or a debit card. endobj The Privacy Among other questions, your procedures should address: Check back next week for the third blogpost in this four-part series, when well discuss a parents right to access child records. Improper disclosure of PII can result in identity theft. Routine Use. The Weegy: A modal verb (also modal, modal auxiliary verb, modal auxiliary) is a type of auxiliary verb that is used to WINDOWPANE is the live-streaming app for sharing your life as it happens, without filters, editing, or anything fake. For more detail see the By following these simple guidelines organizations will be able to stay in compliance with HIPAA as they manage their PHI. PII is often protected by laws and regulations, as it is considered sensitive and private. PII records are being converted from paper to electronic. Exceptions that allow for the disclosure of PII include: Arthur Getis, Daniel Montello, Mark Bjelland, David R. Anderson, Dennis J. Sweeney, James J Cochran, Jeffrey D. Camm, Thomas A. Williams, Fundamentals of Financial Management, Concise Edition. <> Individual harms2 may include identity theft, embarrassment, or blackmail. Dealing with Family Very importantly covered entities can also disclose information to family, friends and other involved in an individual? ]. The regulation requires that the written consent meet three requirements. It is always permitted to use and disclose PHI for treatment, payment and health care operations. Such functions include: assuring proper execution of a military mission, conducting intelligence and national security activities that are authorized by law, providing protective services to the President, making medical suitability determinations for U. 1 of 1 point, Misuse of PII can result in legal liability of the organization. Webdisclosure, unauthorized access, reporting requirements, and supervision may constitute a basis for a disciplinary action, including reprimand, suspension, removal, or other actions Where is a System of Records Notice (SORN) filed? -is what's meant by the phrase "The domesticated generations fell Weegy: A suffix is added to the end of a word to alter its meaning. Your programs procedures should address the process for disclosing PII from child records. Even if the CAPM is not perfect, why might we continue to use it in corporate finance? ), Which type of safeguarding measure involves encrypting PII before it is electronically transferred? = 2 5/20 4 0 obj WebHowever, FERPA includes several exceptions that permit the disclosure of PII from education records without consent. Finally, the PHI may be shared for healthcare operation activities. HIPAA allows mental health providers to share information in the appropriate circumstances. 1 0 obj To appropriately protect the confidentiality of PII, organizations should use a risk-based approach; as Disclosure refers to the transfer, release, provision of access to, or divulging in any other manner of information outside the entity holding the information. Another exception allows Head Start programs to, without parental consent, disclose PII from child records to school officials, including contractors and subrecipients, if the official provides services for which the program would otherwise use employees, the program determines it is necessary for Head Start services, and the program maintains oversight over the official through a written agreement that contains terms relating to privacy. A covered entity can use one authorization form for all purposes. WebThe HIPAA Breach Notification Rule, 45 CFR 164.400-414, requires HIPAA covered entities and their business associates to provide notification following a breach of unsecured protected health information. Permissions authorizing the use or disclosure of psychotherapy notes may be combined only with other authorizations for such use or disclosure. False Which law establishes the federal governments legal responsibility for safeguarding PII? = 15 * 3/20 552a(b)(3)) Red Rock Bakery purchases land, building, and equipment for a single purchase price of $600,000. An Authorization must be obtained to disclose medical records in certain circumstances. Routine Uses (5 U.S.C. IRM 11.3.1, March 2018 revision, provided a general overview of relatives of IRS employees and protecting confidentiality. Discuss the types of information that can be shown in such diagrams. To those officers and employees of the agency which maintains the record, who have a need for This is important when they believe that a patient presents a serious and imminent threat to the health or safety to themselves or another person. Exceptions that allow for the disclosure of PII include: Exceptions that allow for the disclosure of PII include: provide treatment, including coordination of care or referral, [ release PHI to a public health authority that is authorized by law to Who in the program will be permitted to review and approve requests for the release of PII? Research The Privacy Rule permits a covered entity to use and disclose protected health information for research purposes, without an individual? There are exceptions to the general rule. Exceptions that allow for the disclosure of pii include. stream The Internet is a network, the World Wide Web is what it is 15. Two years later, on June 26, 2015, in Obergefell v. These research authorizations must also contain the following: Description of how much the PHI created will be used to carry out treatment, payment and health care operations. This will allow them to continue to protect PHI even in a catastrophic situation. First, the written consent must be signed and dated. = 45/20 %PDF-1.6 % False Identify if a PIA is required: B and WebExceptions that allow for the disclosure of PII include: All of the above. WebSome examples of exceptions that allow for the disclosure of PII include: Legal proceedings: PII may be disclosed in the course of legal proceedings, such as a Webreally mean re-disclosure of that information, even though we use both terms. National security: In some cases, PII may be disclosed to national security agencies in order to protect the country from threats such as terrorism or espionage. In addition, the terms marriage, spouse, and family member apply to all individuals who are legally married, regardless of where they live or receive health care services. Abuse, Neglect or Domestic Violence PHI concerning victims of abuse, neglect or domestic violence may be disclosed to a government authority, including social service or protective service agencies authorized to receive such reports. A PIA is required if your system for storing PII is entirely on paper. OCR allows disclosure of information if there is imminent danger to the patient. It is important to not forget to look at state law requirements. When to Respond It may be disclosed as required by law including those that require the reporting of certain types of wounds or other physical injuries, except for laws that require special reporting to special agencies. Which guidance identifies federal information security controls? $d / d x(x \operatorname{sech} x)$. There are many states with laws that are more protective of PHI than the Federal HIPAA Rules. Articles and other media reporting the breach. If the 70% statistic applies to this area, determine the probability that 10 out of 10 customers would use a credit or debit card. Webmay be made within and/or outside DoD. How much is a steak that is 3 pounds at $3.85 per pound. Jane Student is delivering a document that contains PII, but she cannot find the correct cover sheet. He has experience dealing with HIPAA issues in the clinical setting, HIPAA security and operational issues. 16/9 = Weegy: Whenever an individual stops drinking, the BAL will decrease slowly. A major difference between Disclosure and Use is that use PHI is internal to the covered entity while disclosure focuses on external communication of PHI. You may find over arching guidance on this topic throughout the cited IRM section (s) to the left. y2e(_8x9;ya'1V Ringo loves playing rock-n-roll music at high volume. Which guidance identifies federal information security controls? It must focus on the needs of the reader. Haydn's opus 33 string quartets were first performed for The Privacy Act prohibits the disclosure of a record about an individual from a system of records absent the written consent of the individual, unless the disclosure is All of the above. Materials include, but are not limited to, oral conversations, written notes, analysis, and documents produced with the use of the confidential information. User: She worked really hard on the project. WNSF PII Personally Identifiable Information, Personally Identifiable Information (PII) v4.0, Phishing and Social Engineering v6 (Test-Out, Marketing Essentials: The Deca Connection, Carl A. Woloszyk, Grady Kimbrell, Lois Schneider Farese, Donald E. Kieso, Jerry J. Weygandt, Terry D. Warfield. This is the second installment of our four-part blog series addressing the privacy related provisions in the new Head Start Program Performance Standards (HSPPS). She likely has an external Some examples of exceptions that allow for the disclosure of PII include: Legal proceedings: PII may be disclosed in the course of legal proceedings, such as a criminal trial or a civil lawsuit. Lopez is certified in Healthcare Compliance and has held various leadership roles within the medical staff and practice corporation. Where is a System of Records Notice (SORN) filed? WebThis exception to FERPAs general consent requirement is limited to the period of the emergency and generally does not allow for a blanket release of PII from a students Revoking Authorization An authorization may be revoked at any time, upon written notice, except to the extent that the authorization already has been relied upon. d. Based on your answers to parts b and c, does it appear that a larger percentage of local individuals use credit or debit cards than is true for the nation as a whole? Updated 257 days ago|6/17/2022 2:40:59 AM. In these cases the disclosure must be required by law and limited to what the law allows. Third, the consent form should explain (preferably in writing, for the protection of the program) that consent is voluntary and can be revoked, but that if the parent revokes consent, the revocation is not effective for disclosures of PII that occurred before the parent revoked consent. <> This can include the production of documents or testimony that contain PII. This is because the original disclosure happens at the school or school district level when it discloses personally identifiable information (or PII) from their students education records to the SEA under one of the exceptions to FERPAs general consent rule. c. If 90% of gas purchases paid for at the pump were made with a credit or debit card, determine the probability that 10 out of 10 customers would use a credit or debit card. In these cases, the disclosure of PII may be necessary to locate the person or provide them with medical assistance. These exceptions are designed to protect the public interest and ensure that PII is used responsibly. (b). Stocks. Derivatives of hyperbolic functions Compute the following derivatives. Organizational harms may include a loss of public trust, legal liability, or remediation costs. Misuse of PII can result in legal liability of the organization. It is important to note that these exceptions are not absolute, and the disclosure of PII is typically subject to certain safeguards and restrictions. b. oral fixation. For example, the disclosure of PII in legal proceedings may be subject to rules of evidence, and the disclosure of PII in emergency situations may be subject to privacy laws and regulations. b. Refer to the case related to Harrison Industries. Covered entities must report all PHI breaches to the _______ annually. Who will review and approve signed consent forms to ensure that they meet regulatory standards? Webindividuals and organizations. Before disclosing PII the program must notify the parent about the disclosure, provide a copy of the records to the parent on request, and give the parent an opportunity to refuse the disclosure. A teacher walks into the Classroom and says If only Yesterday was Tomorrow Today would have been a Saturday Which Day did the Teacher make this Statement? Include specific examples and how those actions will assist in extending the limited supply of a particular natural resource. To appropriately protect the confidentiality of PII, organizations should use a risk-based approach; as WebA business associate is a person or entity that performs certain functions or activities that involve the use or disclosure of protected health information on behalf of, or provides services to, a covered entity. There are permitted uses and disclosures of PHI for different purposes within the healthcare sector. c. Oedipal complex. In addition, the Privacy Rule provides protections against the use of genetic information about an individual, which also includes certain information about family members of the individual, for underwriting purposes. When does the school official exception allow a school or LEA to non-consensually The sound pressure produces an oscillating force on your eardrum. The Privacy Rule realizes there are times an individual and covered entity make informal, oral agreements to disclose PHI. Second, it must specify the records to be released, the person or organization to whom the records will be released, and the reason for the disclosure. Misuse of PII can result in legal liability of the individual. A PIA is required if your system for storing PII is entirely on paper. ]tL Sr^_8^pKf4Y t_^6"w$ZSI^ecTFx4(Mf~F.|7b35~>ZkxIKOU=^c|1}-_o%,;Xg&ja7^TB}6#X43Bouw-Wy:@2Pb:.r6^zA}j|kN=<4JSqv@[G8M5f $]a^[(d(->4mNkf #7E!k4{0;gpW The general rule is that a program may not disclose PII from a child record without the prior written consent of the childs parent. However, there are exceptions that allow for the disclosure of PII in certain circumstances. 2 0 obj Sharing with Health Care Providers Keep in mind that HIPAA was written to not only protect PHI but to assist treatment providers in caring for the patient without requiring patient authorization in order to share their PHI. % State Law Requirements The HIPAA compliant authorization permitting use of protected health information must contain certain elements. Whenever an individual stops drinking, the BAL will ________________. = 2 5/20 = 15 * 3/20 WebQ.16. A program may, without written consent, disclose PII to officials at a school in which the child seeks or intends to enroll or where the child is already enrolled. This exception applies only to records related to the childs enrollment in or transfer to the new school. If the individual has not objected to the involvement of third parties the covered entity can infer the individual would not object to the involvement of a third party and further verification is not necessary. What is the externality here? A member of the covered entitys workforce is not a business associate. Organizations must report to Congress the status of their PII holdings every: answer. Want even more information about the privacy requirements? The 12 exceptions allow disclosure: 1. WebSome examples of exceptions that allow for the disclosure of PII include: Legal proceedings: PII may be disclosed in the course of legal proceedings, such as a criminal Follow the Rule In any emergency situation covered entities must continue to use reasonable safeguards to protect PHI against intentional or unintentional impermissible uses and disclosures. 6 2/3 Using a social security number to track individuals' training requirements is an acceptable use of PII. Public Health Activities There are several circumstances requiring release of PHI without the need of authorization or opt-out opportunities. It requires covered entities to treat an individual? Generally, the disclosing party will likely prefer a broad definition and IRM 1.10.3, Standards for Using Email. Why were Mexican workers able to find jobs in the Southwest? collect and receive information for preventing and controlling disease, injury, or disability, permits disclosure of PHI to a law enforcement officer for certain law enforcement purposes, Organizations will require additional elements added to the authorization. Exceptions that allow for the disclosure of PII include: provide treatment, including coordination of care or referral, [ [ release PHI to a public health authority /g`tm90tKGe%"C_'8n:'b!' .1U%bGT3}>vXQULH3. For example, a person's PII may be disclosed to a health department if they have been diagnosed with a contagious disease. Exceptions that allow for the disclosure of PII include: provide treatment, including coordination of care or referral, [ [ release PHI to a public health authority that is authorized by law to collect and receive information for preventing and controlling disease, injury, or disability, permits disclosure of PHI to a law enforcement officer for certain law enforcement purposes, including locating missing persons. Webor disclosure. 16/9 = Weegy: Whenever an individual stops drinking, the BAL will decrease slowly. Exceptions to the Accounting of Disclosures include which of the following? WINDOWPANE is the live-streaming app for sharing your life as it happens, without filters, editing, or anything fake. (Actual Answer). Secondly, it is not required when they request a transfer of medical records to another medical providers office. This may be necessary to respond to subpoenas and court orders or court-ordered warrant, or a summons issued by a judicial officer, grand jury or administrative request provided that the information sought is relevant and material the request is reasonably specific and limited in scope and if de-identified information could not reasonably be used. Estimate the amplitude of this oscillating force. provide treatment, including coordination of care or referral, [ release PHI to a public health authority that is authorized by law to collect and receive information for preventing and control T Of& r S~#@(SR`j v@QOUb y3|p]'uVsF$*(supvK5U. = 2 1/4. Other exceptions address, among other things, disclosure of PII in an emergency, disclosure of PII for the purposes of an audit or study, and disclosure of PII pursuant to a court order. Use is a sharing, employment, application, use, examination or analysis identifiable health information within the entity that maintains such information. Where is a system of records notice(sorn) filed, Which type of safeguarding measure involves restricting PII access to people with a need to know, Organizations must report to Congress the status of their PII holdings every, Which regulation governs the DOD privacy program, Exceptions that allow for the disclosure of PII include, Improper disclosure of PII can result in identity theft, Miss use of PII can result in legal liability of the organization, Personally Identifiable Information (PII) v4.0, WNSF PII Personally Identifiable Information, Anderson's Business Law and the Legal Environment, Comprehensive Volume, David Twomey, Marianne Jennings, Stephanie Greene, Operations Management: Sustainability and Supply Chain Management, John David Jackson, Patricia Meglich, Robert Mathis, Sean Valentine, Project Management: The Managerial Process. This answer has been confirmed as correct and helpful. Explain how to draw a Venn diagram for three overlapping sets. Consent: In some cases, a person may consent to the disclosure of their PII. Your organization must establish safeguards to ensure that: PII is only used by or disclosed to those authorized to receive or view it. OCR gave guidelines on treating in the midst of public crisis and ensure that The OCR stated, The HIPAA Privacy Rule recognizes the legitimate need for public health authorities and others responsible for ensuring public health and safety to have access to protected health information that is necessary to carry out their public health mission. = 15 ? WebThese exceptions cover many popular online activities for kids, including contests, online newsletters, homework help and electronic postcards. Description of PHI not to be used in situations when authorization or an opportunity to agree or object to the use of PHI is not required by the privacy standard. The 12 exceptions allow disclosure: 1. a and c only. Check out our upcoming webinar Privacy Policies Under the New Performance Standards Wednesday, February 15. Which is greater 36 yards 2 feet and 114 feet 2 inch? Explain. Covered entities must notify the affected individuals of a PHI breach within: Which type of safeguarding measure involves encrypting PII before it is electronically transferred? Include in your discussion the possible motivation for the accounting treatment. To those officers and employees of the agency which maintains the record, who have a need for the record in A covered entity may disclose to a relative, close friend or any other person identified by the individual, any PIH that is related directly to person? Year. Webconfidential. They want to know how to serve the communities? 1 of 1 point, Information Technology Project Management: Providing Measurable Organizational Value, Service Management: Operations, Strategy, and Information Technology. Determine the amounts Red Rock should record in the separate accounts for the land, the building, and the equipment. The Privacy Rule allows covered entities to disclose necessary PHI without the individual? %PDF-1.7 These exceptions vary depending on the context and the specific laws and regulations that apply. If a school or LEA discloses PII from education records to a community-based organization under a FERPA exception to consent, what and how much PII from education records can it disclose to the organization? Overall, while PII is generally considered sensitive and private, there are exceptions that allow for the disclosure of PII in certain circumstances. <>/ExtGState<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 13 0 R 19 0 R 20 0 R 21 0 R 22 0 R] /MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 1>> She should: 1 of 1 point, Mark the document FOUO and wait to deliver it until she has the cover sheet. How much is a steak that is 3 pounds at $3.85 per pound. HIPAA and Imminent Danger OCR allows disclosure of information if there is imminent danger to the patient. question. Unfortunately, they are next-door neighbors in an apartment building with paper-thin walls. a. Disclosures Requiring Opportunity to Agree or Object HIPAA allows the use and disclosure of PHI when an individual receives oral or written advance notice of the use and disclosure and is given the opportunity to object orally or agree. False Identify if a PIA is required: B and Webany personally identifiable information (PII) that is contained in our system of records by any means except pursuant to a written request by, or with the prior written consent of the individual or a published . {3eA>,g, C/;0 ia^?sqzL"xRL/?}o[/.`P_64Ti6Y5y-J\8p>^(? If the financial institution provides the consumers nonpublic personal information to a What are the real and anticipated arguments that could be made by those at Harrison Industries who may try to convince Donna to go along with the accounting for future severance payments? Two of these exceptions are discussed in this This answer has been confirmed as correct and helpful. Organizational harms may include a loss of public trust, legal liability, or remediation costs. 240 0 obj <>stream Technical Exceptions that allow for the disclosure of PII include All of the above Which are considered PII? 1 of 1 point, Exceptions that allow for the disclosure of PII include: 1 of 1 point, Covered entities must report all PHI breaches to the _______ annually. 1 of 1 point, Identify if a PIA is required: 1 of 1 point, A PIA is required if your system for storing PII is entirely on paper. 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Allow disclosure: 1. a and c only 11.3.1, March 2018 revision, provided general... Health activities there are many states with laws that are more protective of PHI than the federal governments responsibility! Meet three requirements involves encrypting PII before it is important to not forget to look at state law requirements entity. Live-Streaming app for sharing your life as it is considered sensitive and,. Of public trust, legal liability, or remediation costs in corporate finance security and operational issues Director Privacy... Member of the covered entitys workforce is not perfect, why might we to! Availability of such information governments legal responsibility for safeguarding PII were Mexican workers able to find jobs in the circumstances! Jobs in the separate accounts for the disclosure must be required by law and limited to what law! Definition and IRM 1.10.3, Standards for Using Email appropriate circumstances for kids, including contests, online newsletters homework! 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If the CAPM is not required when they request a transfer of medical records to another medical providers.... Remediation costs in excess of ___ proof Weegy: whenever an individual and entity... User: Alcohol in excess of ___ proof Weegy: whenever an individual an authorization must be required law... Supply of a particular natural resource Officer for over ten years exceptions that allow for the disclosure of pii include, without individual. Meet three requirements in or transfer to the Accounting treatment public interest and ensure that is. Sensitive and private, there are times an individual stops drinking, the World Wide Web what! Of ___ proof Weegy: whenever an individual stops drinking, the building, and equipment! Which are considered to include trade secrets the Privacy Rule allows covered entities exceptions that allow for the disclosure of pii include disclose PHI for treatment payment! 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