20. If my organization is a Covered Entity under HIPAA, how can I share protected health information with a non-Covered Entity participant, like a social service organization, under the DSA?

The DSA permits sharing PHI between a Covered Entity and non-Covered Entity when you have a valid Authorization from the patient or patient’s representative or the Disclosure is otherwise permitted or required by Applicable Law. (See DSA, Section 6(a); Privacy Standards and Security Safeguards Policy and Procedure). For more information on how Covered Entities can share PHI with non-Covered Entities, please see the State Health Information Guidance (SHIG), particularly SHIG Vol. 1.1: Sharing Behavioral Health Information in California, especially Scenario 4, the scenarios in SHIG Vol. 2.0: Sharing Health Information to Address Food and Nutrition Insecurity in California, and the Data Sharing Authorization Guidance (DSAG) Toolkits.