Physician-Led Utilization Management & Advisory Services
HIPAA, PRIVACY & INFORMATION GOVERNANCE

Protected clinical information belongs in the authorized clinical workflow.

UM Physician Advisors separates public business communications from patient-specific clinical-review information. When protected health information is required for an authorized engagement, information exchange follows the applicable client workflow, governing agreement, privacy requirements, and appropriate safeguards.

INFORMATION-GOVERNANCE PRINCIPLE Protect the patient. Use the approved channel. Limit information to the authorized purpose.
01

Public Website

Public forms and general website channels are for business inquiries. Patient-identifying information and clinical records should not be submitted through public inquiry forms.

02

Contracted Clinical Workflow

Patient-specific review information is exchanged through client-approved channels established for the authorized engagement and review purpose.

03

Engagement-Specific Governance

Privacy, access, permitted uses, information exchange, retention, and related responsibilities are governed by the applicable relationship, agreements, and requirements.

TWO INFORMATION ENVIRONMENTS

Business inquiries and clinical-review operations follow different information pathways.

The public website supports business communication. Patient-specific clinical review begins only within the approved client workflow.

PUBLIC WEBSITE

Business communication only

Use public website channels for consultation, contracting, service questions, and other non-patient-specific business communication.

  • Do not submit PHI or patient-identifying information through public forms.
  • Use business contact information for general inquiries.
  • Move case-specific exchange to the approved client workflow.
CLIENT CLINICAL-REVIEW WORKFLOW

Authorized patient-specific information exchange

When a contracted review requires protected health information, information is handled within the applicable client relationship and authorized workflow.

  • Business Associate Agreements are used when required by the applicable relationship.
  • Uses and disclosures follow the governing agreement and applicable requirements.
  • Access and workflow safeguards are aligned to the authorized review purpose.
CLINICAL INFORMATION GOVERNANCE

Govern the information around the review—not just the review itself.

Information handling should be defined before patient-level review begins and remain aligned to the authorized purpose throughout the engagement.

01

Appropriate Secure Workflow

Patient-specific clinical information is exchanged through client-approved channels established for the review program—not through the public business-inquiry form.

02

Business Associate Framework

When UM Physician Advisors functions as a business associate, PHI is handled within the applicable HIPAA requirements and Business Associate Agreement.

03

Purpose-Appropriate Access

Information access and exchange should be limited to the authorized review purpose and aligned with applicable minimum-necessary requirements and exceptions.

04

Safeguards & Accountability

Clinical-information workflows should incorporate appropriate administrative, technical, and physical safeguards, with defined access and accountability responsibilities.

05

Incident & Escalation Responsibilities

The engagement should define applicable notification, escalation, investigation, and response responsibilities for privacy or security events.

06

Retention & Disposition

Record retention, return, destruction, and disposition expectations should be defined according to the governing agreement and applicable requirements.

INFORMATION-GOVERNANCE PRINCIPLE Protect the patient. Use the approved channel. Apply the governing agreement and privacy requirements.
DOWNSTREAM INFORMATION GOVERNANCE

Vendor and subcontractor responsibilities should follow the authorized workflow.

If another party creates, receives, maintains, or transmits protected information as part of an authorized engagement, applicable downstream privacy, security, contractual, and Business Associate requirements should be addressed before that workflow is used.

01

Defined Role

Clarify what information the party may access, why access is required, and what responsibilities apply to that role.

02

Approved Workflow

Use only the systems, channels, and information-exchange pathways authorized for the engagement.

03

Contractual Alignment

Address applicable confidentiality, privacy, security, Business Associate, retention, and incident obligations in the governing arrangements.

MINIMUM NECESSARY & PURPOSE

Access should match the authorized review purpose.

Where the HIPAA minimum-necessary standard applies, reasonable efforts should limit PHI used, disclosed, or requested to what is necessary for the intended purpose, subject to applicable exceptions. Access should also be aligned to the individual’s authorized role and review responsibilities.

RELATED GOVERNANCE RESOURCES

Continue into the clinical-review governance framework.

Review the quality, compliance, coverage, patient-status, and medical-necessity frameworks that support physician review.

Need physician-review capacity within a defined information-governance workflow?

Discuss review scope, secure information exchange, coverage needs, and operational requirements for an authorized engagement.

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