Regarding issue number 2. In the guidance put out July 6th of 2001, under the 'Minimum Necessary' section is a specific question and example that covers this situation. The students will fall under 'health care operations'. The rule provides for "conducting training programs in which students, trainees, or practitioners in areas of health care learn under supervision to practice or improve their skills as health care providers".
Hope this helps. Thank you, Eric Arnett Director of Information Technology Jewish Home for the Elderly of Fairfield, Inc. 175 Jefferson Street Fairfield, Connecticut 06432 P:203-396-1053 F:203-365-6452 E:[EMAIL PROTECTED] IMPORTANT: The information contained in this e-mail message is confidential and is intended only for the named addressee (s). If the reader of this e-mail message is not an intended recipient (or the individual responsible for the delivery of this e-mail message to an intended recipient), please be advised that any re-use, dissemination, distribution or copying of this e-mail message is prohibited. If you have received this e-mail message in error, please reply to the sender that you have received this e-mail message in error and then delete it. Thank you. -----Original Message----- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Monday, February 04, 2002 10:58 AM To: [EMAIL PROTECTED] Subject: Question on non-employees' access Are the following scenarios covered by "consent...for treatment and operations", or by "business associate agreement", or is a "signed authorization" required??? Situation 1: A "non-hospital employee" vendor representative assists in the surgery room, to explain or train surgeon and/or staff on the equipment used in the procedure. Is this "operations"? Does this require a patient authorization? Likewise Situation 2: A surgery is "observed" by an individual or by a class of students (the patient is not identified), is this covered by "consent ...for operations", or does it require a signed patient authorization? Or is this not covered by HIPAA, since the patient's identifiable information is not disclosed, except for the possibility of seeing the patient's face? John L. Schwarz I/S Director, Enterprise Applications --------------------- ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=privacy and enter your email address. ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=privacy and enter your email address.
