Bugarin v. ChartOne, Inc.

RUBIN, J. Concurring.

I concur with the majority opinion, which I have signed, but wish to amplify the observation made by Justice Flier that the effect of our opinion unfortunately increases the cost of medical records to some patients, notwithstanding HIPAA’s intent to do just the opposite. The ruling today upholds the ability of copying services to charge higher rates when the attorney makes the request on behalf of his or her client than when the patient/client makes the request directly. That is, however, as far as the opinion goes. It does not address such presumably common scenarios in which the client signs the request and asks the documents to be sent to the attorney, or the attorney prepares the document on his or her letterhead and the client personally signs the request.

The above examples underscore for me the unintended effect of what purports to be consumer legislation; a resulting tension between a client’s ability to inexpensively obtain medical records and an attorney’s obligation to handle litigation effectively and efficiently for the client. There are no doubt instances in which a client’s interests would be better served by the delivery of important medical records directly to the attorney, thus insuring documents not be lost, statutory procedures for admissibility complied with, and privacy interests respected.

*1567The short answer to this apparent tension is for DHHS to promulgate additional regulations to make clear that the mere fact that the attorney is directly involved in the process does not disqualify the client from the benefits of the cost saving rules. In the meantime and to honor HIPAA’s spirit, it would seem appropriate for the trial courts to give our opinion a narrow rather than an expansive construction.