Communicable Disease Reporting in Michigan

• Communicable Disease Reporting

• Communicable Disease Reporting and HIPAA

Physicians, clinical laboratories, primary and secondary schools, childcare centers, and camps are required to report the occurrence or suspected occurrence of any disease, condition or infection as identified in the Michigan Communicable Disease Rules. In addition, all other healthcare providers are authorized to report to local health authorities. Together, they play a key role in state and local efforts to control communicable diseases. The public health system depends upon these reports of diseases to monitor the health of the community and to provide the basis for preventive action.

Why Report?

Health care providers are required to report communicable disease for several reasons. The most common reasons are listed as follows:

1. To identify outbreaks and epidemics. If an unusual number of cases occur, local health authorities must investigate to control the spread of the disease.
2. To enable preventive treatment and/or education to be provided.
3. To help target prevention programs, identify care needs, and use scarce prevention resources efficiently.
4. To evaluate the success of long term control efforts.
5. To facilitate epidemiologic research to uncover a preventable cause.
6. To assist with national and international disease surveillance efforts. For some diseases that are unusual in Michigan, we are part of a national network that the federal government depends on to determine whether national or international investigations are needed.

Accurate and complete disease reporting is essential to the community health.

What to Report?

To assist health care providers and other institutions in reporting, the Michigan Department of Health and Human Services has prepared separate reporting lists for physicians, clinical laboratories, schools, childcare centers, and camps to provide a quick reference guide of reportable conditions, disease or infections. In addition, Michigan health care professionals and laboratories are also authorized to report any condition, disease, or infection judged by them to indicate that the health of the public is threatened.

A report must contain the following information:

• The patient's full name
• The patient's residential address, including street, city, village or township, county, and zipcode
• The patient's telephone number
• The patient's date of birth (or age) and sex
• The name of the disease, infection, or condition reported and date of onset if known
• The specific laboratory test (if tested), date performed, where performed, and results
• The name and address of the reporting facility

To the extent that the information is readily available, a report of an unusual occurrence, outbreak, or epidemic of a disease, infection, or other condition shall include all of the following information:

• The nature of the confirmed or suspected disease, infection, or condition
• The approximate number of cases
• The approximate illness onset dates
• The location of the outbreak

How and Where to Report?

The presence or suspected presence of all reportable diseases, infections, and conditions are required to be reported to the appropriate local health department. The "appropriate local health department" means:

•  the local health department that has jurisdiction where an individual who has a disease or condition that is required to be reported resides or
• the local health department of the county in which your service facility is located.

In some counties, the local health department where your facility is located desires to have all reports routed through them. Please contact your local health department for further information on the mechanism of reporting for your agency.

Communicable Disease Reporting and HIPAA?

As we are all aware, Health Insurance Portability and Accountability Act of 1996 (HIPAA) was enacted which addressed the sharing of confidential medical information.  This has raised questions among a number of physicians about HIPAA requirements and the reporting of confidential data related to communicable diseases and immunization to local health departments.  The HIPAA legislation does address this question and states that reporting of Communicable Diseases to the local or state health department or immunizations to the Michigan Childhood Immunization Registry are exempt because they are mandated within the Michigan Public Health Code and are used for surveillance and prevention of communicable diseases.  This is addressed in section  §164.512(b) of the HIPAA regulations.  The relevant sections of the Michigan Public Health Code and Administrative Rules are:  

Sec. 333.5111 (1) b - Requirements for reporting communicable and serious communicable diseases

• R 325.173 - Administrative rules detailing the reporting of communicable and serious communicable diseases

• Sec. 33.9207 - Establishment of the Michigan Childhood Immunization Registry R.325.163 - Administrative rules requiring the reporting of immunizations administered to children to the Department.

Physicians who are concerned about reporting communicable diseases and immunizations as required under the Michigan Public Health Code can be reassured that this is permitted under HIPAA and that they are not required to obtain patient written consent before sending this information to the local health department. 

Information from the United States Department of Health and Human Services which explain this section of the regulations can be found at:

http://www.hhs.gov/ocr/hipaa/.