Menorah Park Center for Senior Living v. Rolston
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In this case involving the interplay between the Health Insurance Portability and accountability Act (HIPPA), the subsequent HIPPA Privacy Rule, and Ohio's common-law cause of action for the unauthorized, unprivileged disclosure by a medical provider to a third party of nonpublic medical information recognized in Biddle v. Warrant General Hospital, 715 N.E.2d 518 (Ohio 1999), the Supreme Court held that the patient in this case failed to state a claim under Biddle.
Specifically, the Supreme Court held (1) HIPAA does not preclude a claim under Biddle when the limited disclosure of medical information was part of a court filing made to obtain a past-due payment on an account for medical services; (2) there is an exception to liability under Biddle when a medical provider makes a reasonable effort to limit the disclosure of the patient's medical information to the minimum amount necessary to file a complaint for the recovery of unpaid medical services charges; and (3) the medical provider in this case properly limited its closure of information to the minimum amount necessary to assert a cause of action to recover from the patient payment for unpaid medical bills.
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