Is a health care provider permitted to disclose proof of a child’s immunizations directly to a school without a HIPAA authorization?
Yes, provided the school is required by law to have proof of immunizations in order to admit the child, and a parent, guardian, or other person acting in loco parentis has agreed to the disclosure. See 45 CFR 164.512(b)(1)(vi). Where the individual who is a student or prospective student is an adult or emancipated minor, the provider may make the disclosure with the agreement of the student herself. In either case, the agreement may be obtained orally or in writing, but must be documented (e.g., by placing in the medical record a copy of a written request, or notation of an oral request, from a parent for the provider to disclose the proof of immunization to the school).