I can't say for sure that the
dynamic I've
described is what's happening, but monitoring / filming is a good place to start and will offer more
information for a trainer, should you need to employ one.
We do so for the reasons
described by the commenters and in our NPRM, as well as because we believe that the approach in the final rule creates a logical, consistent system of protections that recognizes the
dynamic nature of health
information use and disclosure in a continually shifting health care environment.