Q&A: HIPAA-compliant filing systems

Q: We still use a color-coded filing system at my organization that uses specific colors to identify patient types, like whether an individual is a Medicaid/CHIP patient. These files are mostly used for billing documentation. Because the colors identify patient type, would this be considered a HIPAA violation? 

A: No, this does not violate patient privacy. Specific billing information is contained within each individual file, so color-coding the file folder for the billing type is acceptable.

Editor’s note: Mary D. Brandt, MBA, RHIA, CHE, CHPS. Brandt is a healthcare consultant specializing in healthcare regulatory compliance and operations improvement. She is also an advisory board member for BOH. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions. Opinions expressed are those of the author and do not represent HCPro or ACDIS. Email your HIPAA questions to revenuecycledaily@hcpro.com