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Associate Contract
Schuyler House is both in philosophy and official policy compliant
with the provisions if the HIPAA regulation. However we feel it
is prudent to advise you of a matter not covered by those regulations.
As part of our Technical Support, Schuyler House occasionally
obtains copies of all or part of the database of our client laboratories.
These copies are for the specific purpose of troubleshooting a
problem that is unique to a particular facility. This data may,
but does not always, include demographic information and patient
results. At Schuyler House, this data is kept secure per HIPAA
regulation.
However, if a laboratory has failed in their stated responsibility
to maintain a backup copy of their database, we sometimes return
this data to the laboratory, at their request.
An example of this is an instance in which a facility was struck
by lightening and their server totally destroyed. We then discovered
that they had never backed up their database. Only the accident
that we had a copy of their databases (obtained some months earlier
for troubleshooting purposes) allowed them to recover any of their
past patient information.
It must be clearly understood that, in such instances, we do not
affirm the accuracy of patient information. In the course of troubleshooting
a problem, our technical staff will frequently change a result
on our copy of a database. This alteration is subsequently saved
as part of our copy.
We regard our ability to occasionally provide an old copy of a
database as an exceptional occurrence. We do not guarantee this
to our clients. If a client fulfills their responsibility of maintaining
a backup of their data, this situation will never occur.
Because it is impossible for us to guarantee the accuracy of any
result in our copy of a client's database, we never disclose
results to an individual. Only the patient's physician would
be able to determine if that particular result was one that had
been altered as part of our troubleshooting efforts, or if it accurately
reflected the patient's condition.
On those occasions when it has been necessary to recover a site's
data with our in-house copy, we have discussed this in detail with
the management of the laboratory. However, as your business associate
agreement makes direct reference to the availability of our potential
copies of your data, a written record of the status of our data
is appropriate.
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