Greeting to all,
Scenario:
State send eligible medicaid member name "John Doe" to Health Plan (HP) A.
Then HP-A distribute it to contracted HP-B. From here, HP-B assigns the member to IPA-X.
Questions:
Who should send the Privacy notice to "John Doe"? The State/HP-A/HP-B/or IPA?
If all of above, then the member will receive 4 privacy notice as of enrollment as a member and another one from Physician as of being a patient? (Total 5 Privacy notice?)
I understand that Providers/physicians under one IPA can agreed to use one privacy notice, then the total can be reduced to 4.
Is there a way, legally, to make it simpler? For example, Joint Notice from State or HP-A to cover all, so that HP-C and IPA do not need to send the repeated notice?
Or the member have to receive all those 4 different privacy notice due to different health care operation and interest in regards to member PHI?
Any insight would be helpful.
Thank you in advance.
Fify Taslim, MD, MBA
C1st MIS Department
Ph. (626) 299-4299 ex.339
Fx. (626) 458-0415
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