What constitutes “disclosure” of PHI under HIPAA?

The definition of “disclosure” of Protected Health Information (PHI) under HIPAA encompasses any instance where PHI is released, transferred, or provisioned to parties outside of the covered entity’s operations. This implies that for HIPAA compliance, any interaction whereby PHI is shared with external entities—be it for treatment, payment, or healthcare operations—constitutes a 'disclosure.' This is critical for ensuring that individuals' health information is appropriately safeguarded, allowing them to maintain privacy rights while still enabling essential communication necessary for their care.

Internal sharing of PHI within the covered entity is not classified as a disclosure because it falls under the operational processes that the entity uses to manage health information internally, which are regulated differently. Monitoring access and archiving PHI for future reference do not involve releasing data externally, which is necessary to meet the criteria for disclosure. Therefore, the correct answer emphasizes the importance of understanding the boundaries of data sharing and the protections that HIPAA mandates for safeguarding patient information when it moves beyond the confines of the organization.