Are Patient Sign-In Sheets a HIPAA Violation

July 29, 2018
Rick Gawenda

A question I have been receiving lately involves patient sign-in sheets and are these sign-in sheets a Health Insurance Portability and Accountability Act (HIPAA) violation? To answer this question, I will quote the Centers for Medicare and Medicaid Services (CMS).

CMS stated in 2002 that covered entities, such as physician’s offices (this would also include therapists in private practices and nonprivate practices), may

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  1. Thank you for this information. Are sign-in sheets absolutely still necessary? I have found that some medical practices are no longer having patients sign-in and I was wondering if it was a task that could be eliminated.

    Thank you,

      1. Thank you, I was asking if sign in sheets were required. If they are not, how can we support a patient was treated on a certain day if questioned? For instance, when patients receive a bill, I have seen them state they were not treated on that day…so I produce the sign in sheet with their signature. Just curious what most practices are doing.

        Thanks again!

        1. Sign-in sheets are not required. How you would support the patient attended therapy would be up to your organization to do. Many organizations use the sign-in sheets as proof the patient at least showed up for their appointment.

  2. Do you know what the upcoming CMS changes for PQRS will entail? I understand the changes will include OP rehab. We are hospital-based OP rehab departments that file to Part A under a group PTAN and group NPI.
    So, at this time, we are not eligible to participate in the current program.

    1. I assume you mean MIPS and not PQRS? If yes, MIPS will only apply to therapists in private practice.