Can One Release of Information Authorize Multiple People or Providers?
It’s a Simple Question with a Complicated Answer
A therapist recently reached out after reviewing a signed Release of Information (ROI). At first glance, she said, everything appeared appropriate, until one line stood out as concerning. The client had authorized disclosure to:
“Any family member or health-affiliated office.”
The intention was clear. Most likely, the client wanted to simplify the process by covering everyone important in her life with one signature and avoid additional paperwork. But something didn’t sit right.
The therapist found herself wondering, “I’ve never seen this before. Is it appropriate? Would this hold up if it were ever questioned?”
She was right to ask the question. If you’ve ever reviewed documentation that feels almost right, but not quite, trust your gut. Don’t take the easy way out. If you’re not sure, check with an expert.
Why “Keeping It Simple” Is So Tempting
This kind of broad language is attractive. Everyone’s burdened with paperwork. Both clinicians and clients long for fewer forms, fewer signatures, and less “stuff” to keep track of.
It would be convenient if one ROI could cover family members, providers, and anyone else involved in the client’s care. One signature and done.
But compliance, especially around client confidentiality, doesn’t bend to convenience.
Where the Problem Begins
The issue isn’t the client’s good intention. It’s specificity.
When substance use disorder (SUD) information is involved, providers must comply not only with HIPAA, but also with 42 CFR Part 2, which requires a higher standard of precision for disclosures.
Even with recent regulatory updates aligning these frameworks more closely, one principle remains unchanged:
Clients must have clear, informed control over who can access their information.
This is where phrases like “any family member” or “anyone involved in my health care” fall apart.
In everyday language, it feels straightforward. In legal and clinical language, it’s an invitation to trouble. “Family” could refer to a spouse, a parent, a sibling, or someone the client hasn’t spoken to in years. There’s no defined boundary, which makes the authorization difficult to interpret and even harder to defend if challenged.
The same issue applies to “any health-affiliated office.” It’s too inclusive and lacks clarity. It doesn’t specify who is authorized. Who has access to private health information is open to the provider’s interpretation, when the control should be in the client’s hands.
There’s even a practical clue many clinicians recognize: ROIs typically require specific contact details; names, phone numbers, street and email addresses. That requirement alone signals that broad phrases like “anyone involved” aren’t sufficient.
What’s Changed and What Hasn’t
Recent updates to 42 CFR Part 2 do allow for more flexibility in how disclosures are structured. For example, clients can authorize disclosure to a defined group, such as:
- A care team within a specific organization
- Participants in a coordinated system of care
This means you don’t always need to list every individual provider by name. But the key word is defined. There’s a meaningful difference between:
- “My treating providers at XYZ Health System”
- “Any health-affiliated office”
One establishes a clear boundary. The other leaves the door wide open.
Back to the Original Question
So, what about that therapist’s situation?
She trusted her gut that something was off and asked someone who knows. An ROI written that broadly does not meet the required level of specificity, particularly when SUD information is involved. In a legal review or audit, there’s a real risk it wouldn’t hold up as intended. The safest and most clinically sound approach is to revisit the form with the client, so it clearly reflects who they want to include.
That might mean:
- Naming specific individuals
- Identifying a particular organization or care team
- Clarifying the scope of disclosure
Just as importantly, it creates an opportunity to reinforce informed consent, helping the client better understand confidentiality and its limits, and strengthening trust in the therapeutic relationship.
It’s a small adjustment. But in terms of compliance and protecting both you and your client it makes a meaningful difference.
Ready to give your clients clear, defined control over their information?
Our Practice Management Forms Package provides the Release of Information forms and documentation tools you need to keep disclosures specific, defensible, and centered on your client’s control. Because clarity about who can access what protects everyone involved.
Beth Rontal, LICSW, a private practice therapist and the Documentation Wizard® is a nationally recognized consultant on mental health documentation. Her Misery and Mastery® trainings and accompanying forms (in English and Spanish) are developed to meet strict Medicare requirements. Beth’s Documentation Wizard training program helps clinicians turn their clinical skill and intuition into a systematic review of treatment that helps to pass audits, protect income, maintain professional standards of care, reduce documentation anxiety and increase self-confidence. Beth’s forms have been approved by 2 attorneys, a bioethicist, and a billing expert and have been used all over the world. She mastered her teaching skills with thousands of hours supervising and training both seasoned professionals and interns when supervising at an agency for 11 years. Her newest initiative, Membership Circle, is designed to empower psychotherapists to master documentation with expert guidance, efficient strategies, and a supportive community.
