I have two concerns with this--first, an authorization must be for a
specific purpose and time-specific, as well, with a start and end date.
Second, no authorization is required for "health care operations" when the
BA is performing tasks "on your behalf", which is why they are Business
Associates.  I am concerned that this is heading down the "not necessary"
path, and creating lots of work and problems that are not required.

Am I missing something?

Carolyn Price



-----Original Message-----
From: Waterhouse, Melissa [mailto:[EMAIL PROTECTED]]
Sent: Wednesday, February 20, 2002 10:39 AM
To: [EMAIL PROTECTED]
Subject: RE: Business Associates and Patient Authorization


We are also looking into an annual authorization for our members that they
can sign at the time of re-enrollment. I would like it to list several
businesses we share information with. Would we need a separate authorization
form for each purpose?

-----Original Message-----
From: McNamee, James [mailto:[EMAIL PROTECTED]]
Sent: Wednesday, February 20, 2002 11:09 AM
To: [EMAIL PROTECTED]
Subject: Business Associates and Patient Authorization


HIPAA regs seem to imply that patients must execute an authorization before
their PHI can be shared with a CE's Business Associate. Various BAs will use
various portions of the PHI for different lengths of time as they perform
the contracted work. Since patient authorizations must be specific -- saying
to whom PHI is released, for what purpose and for how long -- this raises a
practical concern.

If a large organization has scores of BAs to which it releases PHI, does
this organization need to give patients scores of authorization documents to
sign? Or is it permissible under HIPAA to craft a single but less-specific
authorization that would suffice?

________________________________________
James E. McNamee, PhD
Associate Dean of Information Services and CIO
School of Medicine
University of Maryland, Baltimore
Information Services, Room 214
100 N. Greene St.
Baltimore, MD 21201

voice:  410-706-2881
fax:    410-706-4871
e-mail: [EMAIL PROTECTED]

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