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712 Chapter 3:Processes and procedures • Section 5: Program integrity (07/2026) group. This minimum necessary standard does not allow sharing of personally identifying information (such as Social Security number or date of birth), substance abuse information, medical or mental health records or other sensitive information unless the participant to whom the records pertain has authorized access via a written authorization of release of information. The primary person (including non-needy caretaker relatives) and filing group members may only have access to information related to the time during which they had that position in the case. If the family member is not in the filing group, there must be a signed authorization before information may be disclosed to the family member. Information regarding domestic violence should not be shared with family members. Authorization for use and disclosure of information An individual gives consent to share information to identified entities by completing the Authorization for Disclosure, Sharing and Use of Individual Information (MSC 3010). Ideally, this form is signed by the participant in the presence of ODHS|OHA staff, but this is not required; this can help facilitate discussion and to ensure the participant understands the form before signing. ODHS|OHA staff should also answer any questions the participant has about the form and explain to the participant their rights to request limitations on the disclosure of any of their information. When approaching a participant to obtain consent, it is important to remember that an individual’s ability to give informed consent will depend on a number of factors, including the benefits and risks of a particular decision. Allowing a worker to talk with a family member about a participant’s individual situation would require a different level of informed consent than consenting to a series of cancer treatments, for example. If a person has an established history of non-verbal communication, they may give permission for a worker to talk with another party about non-intrusive information by giving their usual sign of consent. In such cases, the worker must document their explanation to the participant about what information they intend to give and for what purpose. They must also document the non-verbal method the participant used to indicate consent. There may be barriers to understanding of the release form. These barriers may include physical or mental disabilities, limited English proficiency or literacy challenges. The presence of a barrier to understanding does not necessarily mean the person is incapable of giving informed consent. For an individual who cannot sign their own name, the participant can make a mark such as an “X” or request another person to sign on their behalf. If a person signs on behalf of the participant, the signature should indicate who actually signed, so if participant Mary asks Sue to sign on her behalf, it can be recorded as “Mary, by Sue”. There is no need to obtain a witness for the participant signing the release form unless there are other reasons to do so (e.g., the individual is requesting a witness, mental competency issue). There should only be one record holder per form; each member of a two-adult household would need to sign their own form to consent to disclosure. The form must include the signature of the individual on the form. In situations where a release of information is required, ODHS|OHA may not identify the individual as being a recipient of public assistance until the authorization has been completed. The release of information must include a specific reason for why the information is being shared; information may not be disclosed beyond the purpose stated on the release of information form. ODHS|OHA should not request unnecessary information about a participant, or more than is needed.