A Practical Guide to HIPAA Authorizations for Estate Planning and Probate
HIPAA authorizations are legal documents that allow designated individuals and entities to access a person’s protected health information. In the context of estate planning and probate, these authorizations ensure family members, personal representatives, and legal counsel can obtain medical records needed to make informed decisions, settle an estate, or support incapacity planning. This page explains how HIPAA authorizations function in Tennessee, what they permit, and why including them in your planning documents can prevent delays and disputes when medical information is needed. The goal is to give clear, practical information so you can move forward with confidence.
Many people are surprised to learn that without a properly executed HIPAA authorization, hospitals and medical providers may refuse to share essential health information with family members or legal representatives. When dealing with estate administration, guardianship, or end-of-life planning, timely access to records can affect decisions about care, benefits, and distribution of assets. This page provides an overview of common scenarios where HIPAA authorizations matter, how they interact with powers of attorney and advance directives, and steps you can take to make sure your medical privacy directives match your overall estate plan and intentions.
Why HIPAA Authorizations Matter in Estate Planning
Including HIPAA authorization language in estate planning documents gives named agents and fiduciaries clear legal authority to obtain medical information when necessary. This reduces confusion among providers and family members and prevents administrative roadblocks during critical moments. Access to medical records can clarify a person’s decision-making capacity, confirm diagnoses that affect asset distribution, and support claims for benefits or insurance. Well-drafted authorizations also limit unnecessary disclosure by being explicit about who may receive information and for how long, providing a balance between privacy and the practical needs of administering affairs.
About Jay Johnson Law Firm and Our Approach to HIPAA Authorizations
Jay Johnson Law Firm assists clients in Benton County and across Tennessee with practical estate planning documents, including HIPAA authorization forms tailored to the client’s goals. The firm focuses on making sure medical release language aligns with powers of attorney, living wills, and probate needs so that authorized individuals can obtain records promptly when circumstances require. Our approach emphasizes plain-language drafting, clear identification of authorized recipients, and coordination with other estate planning documents to reduce ambiguity and avoid delays when medical information becomes necessary for decision-making or estate administration.
Understanding HIPAA Authorizations and Their Role
A HIPAA authorization is a written document that permits healthcare providers to disclose protected health information to specified persons or entities. It differs from broader privacy rules because it represents a patient’s express consent to release information rather than general permitted disclosures. In estate planning, these authorizations can be time-limited or open-ended, and they can identify specific records or categories of information. Understanding the scope and limitations of these forms ensures that family members and legal representatives can access what they need without compromising privacy beyond the intent of the person who signed the authorization.
When integrating a HIPAA authorization into an estate plan, it is important to consider who will be named, how broadly records will be defined, and whether the authorization will survive incapacity or death. Some clients prefer broad access for their personal representative and health care agent to simplify communications; others prefer narrower authorizations to limit disclosure. The document’s language should be aligned with state law and healthcare provider policies to maximize acceptance by hospitals and clinics, especially during emergencies or probate proceedings when timely access is essential for resolving medical or legal matters.
What a HIPAA Authorization Allows and Limits
A HIPAA authorization allows a covered entity to disclose protected health information to a third party named by the patient. The authorization should identify the recipient, describe the information to be disclosed, state the purpose of the disclosure, and include an expiration date or event. It must also inform the signer of their right to revoke the authorization. Despite granting access, a HIPAA authorization does not override other legal protections or substitute for additional documents needed for decision-making or estate administration. Clear drafting helps providers process requests promptly and reduces the chance of misinterpretation.
Key Elements and How Authorizations Are Processed
Effective HIPAA authorizations contain certain core elements: full naming of the individual whose records are requested, identification of the recipient, a detailed description of the records or categories of records covered, the purpose of the disclosure, and a specified duration. Healthcare providers typically require a dated, signed document and may ask for proof of identity from the requester. Many institutions have their own release forms, but a properly drafted authorization that meets HIPAA requirements should be accepted. Knowing the common administrative steps helps avoid delays when records are needed for legal or personal reasons.
Key Terms and Glossary for HIPAA Authorizations
Understanding the terminology that appears in HIPAA authorizations makes it easier to execute and use these documents correctly. This glossary explains common phrases and legal concepts encountered when requesting medical records, such as covered entities, protected health information, personal representative, and revocation. Clear definitions reduce uncertainty among family members and fiduciaries, helping them recognize when and how to act. Familiarity with these terms also aids communication with healthcare providers and reduces the risk of unnecessary denials or procedural hurdles when records are requested for estate or probate matters.
Protected Health Information (PHI)
Protected Health Information, often abbreviated PHI, refers to any information held by a covered entity that concerns a person’s health status, provision of healthcare, or payment for healthcare that can be linked to that individual. PHI includes medical histories, lab test results, billing records, and treatment notes. The HIPAA authorization must clearly describe the PHI to be disclosed so providers understand the scope of the request. Being specific about dates, types of records, or categories of treatment can reduce confusion and ensure the requester receives the relevant documents needed for estate planning, probate, or benefit claims.
Recipient
The recipient named in a HIPAA authorization is the person or entity authorized to receive protected health information. Common examples include family members, personal representatives, trustees, attorneys, and insurance companies. The document should include full legal names and, if appropriate, titles or roles to reduce ambiguity. Providers often verify the identity of the recipient before releasing records. Carefully identifying recipients helps ensure that the information is delivered to the correct person and used appropriately for the intended purpose, such as supporting medical decision-making or handling probate matters.
Covered Entity
A covered entity under HIPAA is a healthcare provider, health plan, or healthcare clearinghouse that electronically transmits health information. Hospitals, clinics, physicians, and many insurance companies are covered entities and are required to comply with HIPAA privacy rules. When requesting records, the authorization should be presented to the appropriate covered entity, which will then follow its internal procedures for verifying the request and releasing records. Understanding which organizations qualify as covered entities helps the requester know where to submit the authorization and what to expect in terms of process and timing.
Revocation
Revocation is the act of withdrawing a previously granted HIPAA authorization. An individual can revoke an authorization in writing at any time, subject to certain legal exceptions, and should provide the revocation to the covered entity responsible for the records. Providers may continue to rely on disclosures made before the revocation was processed. Including clear instructions about revocation and how it should be delivered can prevent misunderstandings and ensure that the document reflects the current wishes regarding access to medical information during estate administration or personal decision-making.
Comparing Limited and Broader Release Options
When preparing a HIPAA authorization, individuals can choose between a narrowly tailored release that targets specific records and recipients, or a broader release that grants wider access to a range of information for a named agent. Narrow releases reduce the risk of unnecessary disclosure but may require additional requests later, which can slow processes during urgent situations. Broader releases simplify access for fiduciaries and personal representatives but require careful consideration of who is authorized. Comparing these approaches involves balancing privacy concerns with practical needs for timely access to records during estate administration or when making health care decisions.
When a Narrow HIPAA Release Is Appropriate:
Limited Release for Specific Matters
A limited HIPAA authorization works well when only certain documents are needed, such as records related to a specific diagnosis, treatment episode, or billing period. This focused approach helps protect broader medical privacy while still providing necessary information for a discrete legal task, such as proving a medical condition for an insurance claim or clarifying a single transaction in probate. For many families, targeted releases are a prudent first step because they address immediate needs without opening the door to more extensive disclosure of the individual’s complete medical history.
Narrow Releases to Satisfy Third-Party Requests
A limited release can also be appropriate when a third party, like an insurance company or a benefit provider, only requires specific information to process a claim. By defining exact document types and date ranges in the authorization, you preserve overall confidentiality while facilitating the required administrative process. This approach reduces the likelihood of unnecessary records being shared and can prevent delays caused by requests for overly broad access, because providers can identify and supply only the documents listed in the authorization rather than searching through a person’s full medical history.
When Broader HIPAA Authorizations Make Sense for Planning:
Broad Access for Fiduciaries
Broad HIPAA authorizations are often appropriate when a designated agent or personal representative must manage ongoing care, make medical decisions, or handle complex estate matters that require access to full health records. Granting wider access reduces the need for repeated releases and expedites communication between providers and those managing affairs. For estate administration that involves medical claims, long-term care coordination, or contested issues about capacity, a comprehensive authorization can help fiduciaries act quickly and effectively without repeatedly navigating administrative hurdles to obtain necessary documentation.
Preparing for Incapacity and Probate
When planning for potential incapacity or when estate settlement may depend on medical histories, a broader HIPAA authorization ensures that appointed representatives can obtain the records needed to make fully informed decisions and to support probate filings. This is especially helpful when timelines are tight or when documentation is required to establish the circumstances surrounding illness or treatment. Including broader release language can avoid repeated administrative steps and help keep legal and medical proceedings moving forward in a coordinated way when the stakes are high.
Benefits of Choosing a Broader Authorization Strategy
A broader authorization approach reduces administrative friction by allowing named agents immediate access to a person’s health records without repeated permissions. This can be particularly valuable in emergencies, during transitions of care, or when settling an estate that depends on medical documentation. Broad authorizations also reduce the risk of disputes among family members by clarifying who may receive information. While privacy considerations remain important, well-drafted broader releases can include limits such as time frames or specific purposes to provide balance between accessibility and confidentiality.
Another advantage of a comprehensive authorization is consistency: When the same individuals are clearly authorized across all planning documents, healthcare providers and institutions can process requests more predictably. This coherence lowers the chance of delays in obtaining records, which may impact decisions about care, benefit claims, or probate timelines. Properly crafted language also helps third parties understand why the information is being requested, improving cooperation and minimizing back-and-forth that can prolong legal or medical processes during critical periods.
Faster Access to Medical Records
When an authorization is broad enough to cover common categories of records, providers can release necessary documents without repeated verification, which helps fiduciaries act quickly. Speed is often essential when dealing with medical decision-making, insurance claims, or deadlines in probate administration. Faster access reduces administrative burdens on family members and legal representatives and ensures that important decisions are supported by accurate and timely information. Including clear identification of the individuals authorized to receive information helps streamline the process at the point of request.
Reduced Administrative Burden During Probate
During probate, administrators often need medical records to establish dates of illness, validate claims, or support distributions tied to health-related events. A broad authorization reduces the number of separate requests and follow-up communications required to gather that documentation. This can shorten the time it takes to resolve estate matters and reduce legal and administrative costs. A well-integrated authorization, consistent with other estate planning documents, helps probate proceed with fewer obstacles and makes it easier for administrators to meet court timelines and requirements.
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Practical Tips for Handling HIPAA Authorizations
Name Recipients Clearly
When drafting a HIPAA authorization, include full legal names and, where relevant, relationship or role descriptions such as personal representative or trustee. Avoid vague references like “family” or “relatives”; providers may refuse to process a release that does not identify a specific recipient. Clear naming reduces administrative delays and helps ensure the request is accepted on first submission. If you anticipate multiple people needing access, list them individually and consider whether each should have the same scope of access or different, more limited permissions based on their role.
Specify the Records or Purpose
Coordinate with Other Planning Documents
Make sure HIPAA authorization language aligns with powers of attorney, advance directives, and estate planning instruments so authorized agents have consistent authority across documents. Conflicting or inconsistent language can cause providers to hesitate before releasing records, so harmonizing the documents reduces ambiguity and supports smoother administration. If needed, include cross-references that explain how the authorization relates to other documents, and keep copies where appointed agents and healthcare providers can access them quickly in an emergency.
Reasons to Include HIPAA Authorizations in Your Plan
Including a HIPAA authorization in your estate planning documents ensures that appointed agents and personal representatives can obtain medical records needed for decision-making, benefits administration, and probate. Without such an authorization, families may face delays or denials from hospitals and clinics that are bound to protect patient privacy. A properly drafted authorization reduces uncertainty, clarifies who may receive information, and helps third parties understand the reason for the request. This preparation can save time and stress during critical moments where timely access to records matters for health or legal outcomes.
Additionally, having clear HIPAA authorization language can help prevent disputes among family members by designating who is allowed to obtain records and for what purposes. This reduces the risk of competing requests and potential conflicts during probate or when making health decisions. A thoughtful authorization can include reasonable limits such as expiration dates or narrow categories of records while still enabling essential access. Planning ahead with these documents can streamline processes and give appointed individuals the tools they need to act on your behalf when necessary.
Common Situations Where HIPAA Authorizations Are Useful
HIPAA authorizations commonly become important in situations like hospitalizations, determination of decision-making capacity, insurance or disability claims, and probate proceedings. When someone is incapacitated, their healthcare agent or personal representative may need records to coordinate care, evaluate treatment options, or support legal filings. In probate, medical records can document illnesses or treatment timelines that bear on estate administration. Having signed authorizations ready avoids delays and makes it easier for appointed individuals to obtain the information they need promptly and with less administrative friction.
Hospitalization or Acute Care Needs
During hospitalization or acute medical incidents, quick access to prior records can inform treatment decisions and reveal allergies, preexisting conditions, or past interventions. A signed HIPAA authorization allows designated individuals to obtain records and communicate with providers on the patient’s behalf. This is particularly important when immediate family members need to coordinate care or confirm the patient’s medical history. Having the authorization accessible ahead of time minimizes delays and helps medical teams and family members make timely, informed choices about care and follow-up.
Filing Insurance or Benefit Claims
Insurance and benefit claims often require medical documentation to prove the nature and timing of treatment. When a personal representative or attorney is handling a claim, a HIPAA authorization enables them to obtain the necessary records directly from providers, which can speed up processing and reduce reliance on third-party subpoenas or court orders. Clear authorization language that specifies the purpose as claims or benefits can help providers prioritize and release the correct documents, improving the chances of a timely resolution of financial and administrative matters tied to health events.
Probate and Estate Administration
Medical records are often relevant in probate to establish dates, conditions, or treatments that affect estate distribution or creditor claims. A HIPAA authorization gives an executor or administrator a straightforward way to obtain these records when needed to support filings, defend against disputes, or verify claims. Having this authorization ready as part of the estate planning package can reduce delays in probate, help comply with court requests, and provide the factual basis needed to settle complex matters involving health-related claims or asset distribution tied to medical circumstances.
Local Assistance for HIPAA Authorizations in Camden
If you need help preparing HIPAA authorizations in Camden or Benton County, Jay Johnson Law Firm can assist in drafting clear, effective release language that aligns with your estate plan. We focus on practical documents that providers will accept and that give appointed agents the access they need without unnecessary exposure of medical details. Whether you require a narrow or broader authorization, we can help you choose the right scope, coordinate with other planning documents, and provide guidance on presenting requests to healthcare institutions to reduce administrative delays when records are needed.
Why Clients Choose Jay Johnson Law Firm for HIPAA Authorizations
Clients work with Jay Johnson Law Firm because the firm emphasizes clarity and coordination in estate planning documents, including HIPAA authorizations. We aim to create language that healthcare providers will accept and that integrates smoothly with powers of attorney and advance directives. By anticipating common administrative hurdles and drafting to reduce ambiguity, the firm helps minimize delays when records are requested, which is particularly helpful during medical emergencies and probate proceedings when time-sensitive information is required.
The firm’s practice includes advising on practical choices about the scope of authorizations, including whether a narrow, purpose-limited form or a broader release best fits the client’s needs. We explain the trade-offs related to privacy and access and provide strategies for naming recipients, setting expiration terms, and coordinating revocation instructions. Our objective is to give clients documents that are usable in real-world situations by family members, personal representatives, and institutions responsible for releasing records.
In addition to drafting, the firm offers guidance on the procedural aspects of requesting records, such as where to submit authorizations, what identification is typically required, and how to handle provider-specific release forms. This practical support helps appointed individuals avoid common administrative delays and ensures they have the information they need to act promptly on behalf of the person whose records are sought, whether for care, benefits, or estate matters.
Get Help Drafting a HIPAA Authorization That Works
How We Handle HIPAA Authorization Requests and Coordination
Our process begins with a review of your existing planning documents and a discussion about who will need access to medical records and for what purposes. We then draft authorization language tailored to those needs, coordinating it with powers of attorney and advance directives to ensure consistency. The firm also advises on practical steps for submitting authorizations to hospitals and clinics, and can prepare multiple copies or provider-specific forms if needed. This approach aims to reduce confusion and speed the release of records when time matters most.
Step One: Information Gathering
The first step is gathering relevant information about the person whose records may be requested and the likely recipients. This includes legal names, relationships, preferred expiration terms, and any specific categories of records that should be covered. We also review any existing advance directives or powers of attorney to identify overlapping or conflicting language. This initial information-gathering stage ensures the authorization reflects the client’s wishes and anticipates the kinds of records and situations that will require disclosure, preventing unnecessary revisions later on.
Discussing Scope and Recipients
During this discussion, we focus on who will need access and how broadly they should be authorized. We explore whether a single broad authorization or multiple narrow releases would better protect privacy while meeting practical needs. We consider scenarios such as emergency access, insurance claims, and probate to determine the appropriate scope. This conversation helps tailor the document so that it is both functional for appointed agents and mindful of personal privacy preferences, ensuring the authorization aligns with the overall estate planning goals.
Reviewing Existing Documents
We review existing estate planning and medical decision documents to ensure consistent language and authority across all instruments. This prevents conflicting instructions that might cause healthcare providers or institutions to hesitate when processing requests. By aligning the HIPAA authorization with powers of attorney, advance directives, and beneficiary designations, we create a cohesive set of documents that clarifies who may act and how. This thorough review reduces the need for amendments and prepares the client for smoother interactions with providers when records are requested.
Step Two: Drafting the Authorization
After gathering information, we draft the HIPAA authorization with clear, concise language identifying the person whose records are covered, the named recipients, the specific records or purposes, and any expiration or revocation instructions. We tailor the document to meet HIPAA requirements and to be acceptable to local healthcare providers. Where appropriate, we draft both a general authorization and narrower versions that target specific needs, ensuring clients have options to address different situations without compromising privacy more than necessary.
Creating Provider-Friendly Language
We draft language designed to be quickly understood and accepted by hospitals, clinics, and other covered entities. This includes explicit descriptions of records, clearly identified recipients, and a stated purpose for the request. Provider-friendly authorizations reduce back-and-forth and limit additional paperwork. Where institutions use their own release forms, we adapt our language to the provider’s requirements while preserving the client’s intended scope, helping ensure that requests are processed efficiently when records are needed for care or legal matters.
Including Practical Administrative Details
A practical authorization includes instructions for revocation, an expiration date or event where appropriate, and any supporting documentation that providers may request when releasing records. We advise clients on identification requirements and on keeping signed copies accessible to authorized individuals. Including these administrative details helps prevent delays and ensures that appointed agents understand how to present requests, what identification to provide, and where to submit the authorization for faster processing by covered entities.
Step Three: Execution and Implementation
The final stage involves signing the authorization in the presence of any required witnesses and distributing copies to the named recipients and to relevant healthcare providers. We recommend keeping original signed copies in a secure but accessible location and providing certified copies or provider-specific forms when requested. We also advise clients on revocation procedures and on updating authorizations when circumstances change, such as when relationships shift or when the scope of access should be narrowed or expanded to meet evolving needs.
Signing and Distribution
After drafting, the authorization should be signed and dated according to HIPAA requirements and any provider-specific rules. We provide guidance on how to present the document to healthcare institutions and on whom to give copies to so that authorized individuals can access records without delay. Responsible distribution helps ensure that providers recognize the authorization when requests are made and that named recipients can act quickly when medical or estate matters arise.
Maintaining and Updating Authorizations
Authorizations should be reviewed periodically and updated as circumstances change, such as when authorized recipients change or when a client’s preferences about disclosure evolve. We recommend revisiting these documents after major life events such as marriage, divorce, or changes in health status. Keeping authorizations current reduces the risk of disputes and ensures that appointed agents retain the access they need to perform their duties without encountering outdated or conflicting instructions when records are requested.
Frequently Asked Questions About HIPAA Authorizations
What is a HIPAA authorization and when is it needed?
A HIPAA authorization is a written document that permits a covered entity to disclose protected health information to a designated person or organization. It is needed whenever a patient wants to allow someone else access to their medical records beyond what HIPAA allows without written consent. Typical situations include hospital communication with family members, retrieval of records for insurance claims, or providing documentation during probate.An authorization should identify the person whose records are covered, the intended recipient, a description of the records, and a purpose and expiration. Including these elements helps providers evaluate and act on the request without unnecessary delay. Preparing the authorization as part of estate planning helps ensure access when it matters most.
How does a HIPAA authorization differ from a power of attorney?
A HIPAA authorization specifically permits the disclosure of medical information, while a power of attorney grants legal authority to act on someone’s behalf in financial or health care matters. Although a health care power of attorney names an agent to make medical decisions, some providers still require a separate signed HIPAA authorization before releasing detailed records to that agent. This means that both documents can be important to ensure agents have both decision-making authority and access to the information they need.Coordinating the language between a power of attorney and a HIPAA authorization reduces confusion. When both documents consistently identify the same agent and scope of access, providers are more likely to accept requests without additional paperwork or delays.
Can I limit what records are released under a HIPAA authorization?
Yes, a HIPAA authorization can be limited to specific records, date ranges, or types of information. For example, you can allow disclosure of hospital records from a certain admission, records related to a particular diagnosis, or billing statements. Narrowing the scope helps protect privacy while providing the documents necessary for a particular legal or administrative task.When limiting a release, be precise in your descriptions. Clear descriptions of the records or dates make it easier for providers to identify the relevant files and respond quickly, reducing the need for follow-up requests or clarifications that can delay access.
How long does a HIPAA authorization remain effective?
The effective period of a HIPAA authorization depends on how it is drafted. Some authorizations include a specific expiration date or event, while others remain in effect until revoked. The signer can set a time frame that matches the anticipated needs, such as the duration of an estate administration or until a specific claim is resolved.Because circumstances can change, it is wise to review and update authorizations periodically. If an authorization does not specify an expiration, providers may still treat it as valid until it is revoked in writing, so clear language about duration and revocation is important for both privacy and practicality.
What should I do if a provider refuses to release records?
If a provider refuses to release records, first confirm whether the authorization meets HIPAA requirements and whether the provider has additional documentation needs, such as identification or a provider-specific form. Some institutions have their own release forms and will ask you to complete those even if you have a valid authorization. Addressing any administrative or identification requirements often resolves the issue.If a legitimate authorization is still refused, consider requesting a written explanation from the provider and consult legal counsel about next steps. In some cases, a court order or formal legal request may be necessary, particularly when records are required for litigation or probate and administrative channels have been exhausted.
Can I revoke a HIPAA authorization, and how?
You may revoke a HIPAA authorization in writing at any time, provided the revocation is delivered to the covered entity that holds the records. The revocation should reference the original authorization clearly and be signed and dated by the person who signed the authorization. Providers may continue to rely on disclosures made prior to receiving the revocation, so acting promptly and notifying all relevant institutions is important.To avoid confusion, distribute the revocation to the same providers who received the original authorization and retain proof of delivery. If an agent has already used records obtained before revocation, additional legal steps may be required to address any misuse or further disclosure.
Do hospitals in Camden use their own forms or accept private authorizations?
Some hospitals and clinics in Camden and across Tennessee use their own forms for medical releases and may request that you complete their paperwork even if you have a private authorization. This is often a matter of institutional policy. Providing a properly formatted HIPAA authorization that contains required elements can still be effective, but be prepared to complete provider-specific forms when requested.To minimize delays, ask the provider in advance which form they prefer and include all requested information. Submitting the provider’s form along with a signed HIPAA authorization that aligns with your estate plan can streamline processing and reduce the need for follow-up.
Who should be named as a recipient in an authorization?
Name individuals who will realistically need access to medical records, such as a personal representative, trustee, or close family member tasked with handling benefits or estate matters. Include full legal names and consider listing alternate individuals in case the primary recipient is unavailable. If a trust or organization requires access, include its legal name and the authorized representative.Avoid vague references and ensure roles are clearly identified to reduce provider confusion. When multiple people need access, consider whether each should have the same level of access or if varying levels of authorization are more appropriate depending on their responsibilities.
Will a HIPAA authorization allow access to mental health records?
Mental health records may be subject to additional protections under state or federal laws, but a properly executed HIPAA authorization can permit disclosure of such records if the authorization explicitly includes them. Some providers require specific language or additional consent for psychotherapy notes or highly sensitive mental health information, so specifying these categories clearly in the authorization is important if you intend to include them.Because of additional sensitivities, it is advisable to discuss the inclusion of mental health records with counsel or the provider beforehand, and to be explicit in the authorization about the types of mental health information covered to avoid ambiguity or denial of the request.
How can I make sure my authorization is accepted quickly by providers?
To increase the likelihood that an authorization is accepted quickly, ensure it contains all HIPAA-required elements: identification of the person whose records are at issue, the named recipient, a description of the records, a purpose, an expiration, and a signature with date. Providing copies of identification for the requester and notifying the provider in advance about the incoming request can also help.Additionally, check whether the provider prefers a specific release form and be ready to complete it. Coordinating with the provider’s administrative office and supplying clear, complete documentation helps speed processing and reduces the likelihood of denials based on technical deficiencies.