20. If my organization is a Covered Entity under HIPAA, how can I share protected health information with a non-Covered Entity participant, like a social service organization, under the DSA? [2/21/2023]

The DSA does not require your organization to share protected health information with non-covered Entities, such as a social services organization. The DSA permits sharing between a Covered Entity and non-Covered Entity when you have a valid authorization from the patient or patient’s representative or the disclosure is otherwise permitted or required by applicable law. (See DSA, Section 6(a); Privacy and Security Safeguards P&P). For more information on how Covered Entities can share protected health information with non-Covered Entities, please see the State Health Information Guidance (SHIG), particularly SHIG Vol. 1.1: Sharing Behavioral Health Information in California, especially Scenario 4, and the scenarios in SHIG Vol. 2.0: Sharing Health Information to Address Food and Nutrition Insecurity in California.