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FAQ 1510 Must a health care provider obtain a parent’s agreement before each disclosure of proof of a child’s immunization to a school that is required by a school entry law to have such information?

This is HIPAA Guidance for school immunizations disclosures.

Final

Issued by: Office for Civil Rights (OCR)

Must a health care provider obtain a parent’s agreement before each disclosure of proof of a child’s immunization to a school that is required by a school entry law to have such information?

Answer:

In most cases, it is anticipated that a health care provider will obtain agreement for the disclosure of proof of immunization to a school at the time a particular disclosure is needed.  For example, a parent may call and request that a covered health care provider send proof of his or her child’s immunizations to an elementary school before the child is to begin school.  If that child moves to a different school and is unable to transfer the immunization records to the new school, the parent may then need to request that the health care provider send the child’s records directly to the new school.  However, in some circumstances the scope of the agreement may vary based on the needs of the parent and the school.  For example, a parent may agree to the health care provider making multiple disclosures over a period of time, such as where updates are required by a school when a series of vaccinations have been completed.

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