According to HHS, an accounting of disclosures would encompass both hard-copy and electronic protected health information
that is maintained in a designated record set, while an access report would apply only to information maintained in an electronic
designated record set. HHS defines a designated record set as "a group of records which a covered entity uses to make decisions
about individuals, [including] a health care provider's medical records and billing records, and a health plan's enrollment,
payment, claims adjudication, and case or medical management record systems."