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SESK: Stuff Everyone Should Know · sesk.info/hipaa-accounting-6-years

A patient asks for an accounting of disclosures of their PHI. How far back can it cover?

Six years before the request.

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  1. One year
  2. Six years ✔
  3. Ten years

Why: Patients may get a list of certain disclosures made in the six years before the request. Routine treatment, payment and operations disclosures are left out.

Huh, didn't know that: Disclosures the patient authorized are also left out of the accounting.

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References

Answer: Six years. Patients may get a list of certain disclosures made in the six years before the request. Routine treatment, payment and operations disclosures are left out.

  1. 45 CFR 164.528 (eCFR) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.528
    made by a covered entity in the six years prior to the date on which the accounting is requested
    Checked 2026-10-10.
  2. 45 CFR 164.528 (eCFR) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.528
    Pursuant to an authorization as provided in § 164.508
    Checked 2026-10-10.

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