Do the HIPAA Privacy Rule’s minimum necessary requirements prohibit medical residents, medical students, nursing students, and other medical trainees from accessing patient medical information in the course of their training?

No. The definition of “health care operations” in the Privacy Rule provides for “conducting training programs in which students, trainees, or practitioners in areas of health care learn under supervision to practice or improve their skills as health care providers.” Covered entities can shape their policies and procedures for minimum necessary uses and disclosures to permit medical trainees access to patients’ medical information, including entire medical records.