This thread is in the correct forum, to be sure. Lots of opinions here.
To the extent that the factual situation might interest anyone:
It might not be a violation. The HIPAA regulations at 45 CFR § 160.103 define “Protected Health Information,” and that definition almost certainly covers the specific blood test information you mention. And the doctor’s office is almost certainly a “Covered Entity.” This means, again speaking in likely generalities, that the doctor’s office (“Covered Entity”) may not disclose specific blood test results (“Protected Health Information”) except under certain defined exceptions.
One such exception relates to payment. A Covered Entity can disclose information from a “…health care provider or health plan [in order] to obtain or provide reimbursement for the provision of health care…” (45 CFR § 164.501). To the extent that the named insured has any role in approving expenditures (say, for example, in the case of a jointly-shared spending cap for services) this disclosure would probably be warranted.
Anyone has a right to be upset about anything. But there’s a factual answer to the question, “Is this a HIPAA violation?”
No, not remotely accurate.
At one time, a framework of laws called coverture laws did indeed create the presumption that a married couple were one in many ways; a married woman could not, for example, own separate property and the husband would be liable for many of his wife’s actions. This is humorously highlighted in dialog from Dickens’ Oliver Twist: when Brownlow learns that Bumble has destroyed trinkets that would have shed light on Oliver’s origins, Bumble protests that was his wife and not he who disposed of the objects. Brownlow retorts that he is still the more guilty in the eyes of the law; for the law presumes that your wife acts under your direction. Bumble responds, “If the law supposes that, the law is a ass – an idiot. If that’s the eye of the law, the law is a bachelor; and the worst I wish the law is, that his eye may be opened by experience!”
However, what was true in Dickens’ time is not true today. The spousal privilege is today grounded on the public policy of preserving marital harmony as opposed to forcing a spouse to testify adversely to the interests of his or her partner. As the Supreme Court explained in Trammel v. U.S.: “The ancient foundations for so sweeping a privilege have long since disappeared. Nowhere in the common-law world - indeed in any modern society - is a woman regarded as chattel or demeaned by denial of a separate legal identity and the dignity associated with recognition as a whole human being. Chip by chip, over the years those archaic notions have been cast aside so that ‘[n]o longer is the female destined solely for the home and the rearing of the family, and only the male for the marketplace and the world of ideas.’”