The Minnesota Supreme Court held that a hospital room assignment may qualify as a “health record” under state law when disclosed without a patient’s consent, according to the Star Tribune. The ruling addresses the disclosure in this case; it does not establish a blanket ban on sharing patient information.
The law and the specific disclosure
The Minnesota Health Records Act defines a health record broadly to include information related to a patient’s health or to the provision of health care, according to Minnesota Statutes section 144.291. The dispute was whether telling a caller that Justin Holtzbauer was hospitalized at a particular facility and providing his room and bed numbers fit that definition.
Holtzbauer had opted out of Mercy Hospital’s patient directory in 2022. The Minnesota Court of Appeals’ account says an employee at another Allina facility told his former spouse, identified as H.H., that he was at Mercy Hospital in room 10, bed 3. The appeals court concluded that the information related to the provision of health care and reversed the district court’s decision for Allina, according to the court’s opinion. The Supreme Court upheld that ruling, the Star Tribune reported.
Issues still before the lower court
The case returns to Hennepin County District Court. Remaining questions include whether the disclosure caused Holtzbauer injury and, if so, the amount of damages, according to the Star Tribune. The Court of Appeals also left unresolved whether simply confirming that someone is a patient, without naming a facility or room assignment, would count as releasing a health record; the supplied appellate opinion does not decide that narrower question.
Allina has said the ruling could make communication with families and others more difficult as the health system seeks to protect patient rights and safety, the Star Tribune reported. The decision concerns the disclosure at issue under Minnesota law; it does not determine how every other circumstance or legally permitted disclosure would be treated.
How federal directory rules apply
HIPAA provides a separate framework for permitted directory uses and disclosures. Under the federal rule, an individual must be informed in advance and given an opportunity to agree to, prohibit or restrict a permitted use or disclosure, according to the Electronic Code of Federal Regulations.
