The hospital directory information to which you refer is for current patients and does not apply to patiens who have been deceased for many years.
A deceased person’s medical records are still protected under HIPAA and still require a waiver from a legal representative of the deceased before being released. The hospital cannot automatically tell a private investigator that SAD was never treated in the hospital.
There are also special HIPAA rules regarding the release of PHI when confirming a patient’s admittance in a facility would disclose the nature of the patient’s treatment. For example, if a clinic treats only drug addicts, then confirming a patient’s admittance to the facility discloses the fact that he or she is being treated for substance abuse.
IOW, they have nothing preventing them from talking about SAD??
The hospital cannot automatically tell a private investigator that SAD was never treated in the hospital.
Sure they can. If she wasn't there, they are under no obligation to protect something that doesn't exist.