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A physician is considering using a unique code system in patients’ notes for particularly delicate issues to protect confidentiality. Is this a good idea?
As a family practitioner, I often have patients confide intimate matters, including sexual history and mental health issues, to me. I worry about staff in our group seeing this material and perhaps even sharing it. The practice is direct primary care for cash, so I never have to send charts to insurers. Can I use a code system in my notes for particularly delicate issues so that only I will know what those matters are?
You could take this unusual step but would have to use a pre-set key that applies to all patients because if you ever have to decode the notes because you are being sued or are subject to a Medical Board complaint, it would otherwise be presumed to be self-serving if, for example, you then say that “XJ5” refers to suicidal ideation now that you know that that issue’s role in the patient’s care is central to the allegations against you.
Frankly, rather than trying to set up a system that would defy enigma, it is better to address these concerns with the group.
This is about fundamental compliance with confidentiality under both HIPAA and state law. While office operations or cotreatment may necessitate some overlap in access, no one should be perusing what they are not legitimately working on or have access to more than the minimum protected health information needed for a specific purpose. A biller does not need to know a patient’s STD diagnosis to match appointment dates with balances, and a nurse practitioner providing a routine refill of an anti-anxiety medication that a patient is well-established on does not need to know that the root of the anxiety is childhood sexual abuse.
Your concern for your patients is admirable, but if you have realistic concerns based on practice lapses you have observed, the solution is to work with your colleagues to reinforce proper staff conduct and shore up potential loopholes like IDs that open all files rather than creating personal codes.
