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Even if you do not transmit billing or any clinical data electronically, most experts argue that you may need to be in compliance with the regulations because they are rapidly becoming part of the standard of care. Therefore, many experts and professional organizations recommend that all therapists become compliant regardless of their billing practices.
The Privacy Rule allows, but does not mandate, psychotherapists to keep two sets of records. When two sets of records are used, one set is more general, less private, and more readily accessible to insurers, clients, and others; the more private set is the Psychotherapy Notes. Psychotherapy Notes are primarily more protected notes, which are useful to the therapist who writes them and are maintained separately from the medical record.
If you would like to brush-up on HIPAA's impact on mental health, Dr. Ofer Zur's 6 credit course, HIPAA Compliance Kit - Fifth Edition, is very popular with clinicians in all practice settings.
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