HIPAA Minimum Necessary Standard 1 — Questions and Answers
Question 1: What does the HIPAA Minimum Necessary Standard require covered entities to do when using or disclosing PHI?
- Share the complete medical record to ensure comprehensive care
- Limit PHI to the least amount reasonably needed to accomplish the intended purpose (Correct answer)
- Obtain patient authorization for every internal use of PHI
- Encrypt all PHI before any use or disclosure
Correct answer: Limit PHI to the least amount reasonably needed to accomplish the intended purpose
The Minimum Necessary Standard requires covered entities to make reasonable efforts to use, disclose, or request only the minimum amount of PHI needed to accomplish the intended purpose.
Question 2: Which of the following disclosures is EXEMPT from the Minimum Necessary Standard under HIPAA?
- Disclosures to a health plan for payment purposes
- Disclosures to a business associate for operations
- Disclosures to a treating healthcare provider (Correct answer)
- Disclosures to an employer for workforce management
Correct answer: Disclosures to a treating healthcare provider
HIPAA explicitly exempts disclosures to treating healthcare providers from the Minimum Necessary Standard because treatment requires complete clinical information.
Question 3: Under the Minimum Necessary Standard, what must a covered entity do when it routinely requests PHI from another covered entity?
- Obtain a written authorization from the patient each time
- Establish standard protocols or criteria limiting requests to the minimum needed (Correct answer)
- Request the entire medical record to avoid missing relevant information
- Submit requests only through a certified health information exchange
Correct answer: Establish standard protocols or criteria limiting requests to the minimum needed
For routine requests, covered entities must establish standard protocols that limit PHI requests to what is reasonably necessary for the identified purpose.
Question 4: How should a covered entity implement the Minimum Necessary Standard for internal workforce access to PHI?
- Allow all employees to access any PHI to ensure operational flexibility
- Require all PHI access to go through a privacy officer
- Implement role-based access controls so employees access only PHI needed for their job functions (Correct answer)
- Restrict PHI access only to licensed healthcare professionals
Correct answer: Implement role-based access controls so employees access only PHI needed for their job functions
Role-based access controls ensure each workforce member can access only the PHI necessary to perform their specific job function, satisfying the Minimum Necessary Standard.
Question 5: Which of the following is a valid method for a covered entity to comply with the Minimum Necessary Standard for non-routine disclosures?
- Require the requestor to complete a privacy training course
- Review each non-routine request on a case-by-case basis to determine the minimum PHI needed (Correct answer)
- Automatically deny all non-routine requests as a precaution
- Disclose PHI only in de-identified form for all non-routine requests
Correct answer: Review each non-routine request on a case-by-case basis to determine the minimum PHI needed
For non-routine disclosures, covered entities must make an individual determination of what constitutes the minimum necessary PHI for each specific request.
Question 6: The Minimum Necessary Standard was established under which HIPAA rule?
- The HIPAA Security Rule
- The HIPAA Breach Notification Rule
- The HIPAA Privacy Rule (Correct answer)
- The HIPAA Enforcement Rule
Correct answer: The HIPAA Privacy Rule
The Minimum Necessary Standard is a core requirement of the HIPAA Privacy Rule, found at 45 CFR §164.502(b) and §164.514(d).
Question 7: Which of the following best describes how the Minimum Necessary Standard applies to disclosures required by law?
- Covered entities must still limit PHI to the minimum needed to comply with the legal requirement (Correct answer)
- Disclosures required by law are fully exempt from the Minimum Necessary Standard
- The covered entity must obtain patient authorization before any legally required disclosure
- Legally required disclosures must always include the complete medical record
Correct answer: Covered entities must still limit PHI to the minimum needed to comply with the legal requirement
Even when disclosure is required by law, covered entities must disclose only the minimum PHI necessary to meet the specific legal requirement.
HIPAA Minimum Necessary Standard 1
What does the HIPAA Minimum Necessary Standard require covered entities to do when using or disclosing PHI?