On June 12, 2020, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) published guidance to health care providers regarding whether they can contact patients who have recovered from COVID-19 about blood and plasma donation opportunities. The guidance explains that HIPAA covered entities are permitted to use protected health information to identify and contact those patients for population-based activities related to improving health, case management, or care coordination. Providers are permitted to use PHI for this purpose without authorization only to the extent that these activities do not constitute marketing.
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