Subject+ID+Clarification

Just to provide more specific-  A HIPAA accounting for disclosures is not required when information is released / exchanged for treatment, payment or operations, or when information is released under an authorization.   Since information is being exchanged for treatment purposes or care coordination for VLER, this information does not have to be tracked.   Based upon the existing functionality supported by Exchange today, this information would only be necessary when information is released to CDC for public health purposes. 
 * Mariann Yeager- Clarification**