How to handle Patient Requested Amendments?

[Jim Moores]

Hi All,     Those of us on the Privacy Project Team at my company are discussing how should we record subscriber requested amendments.     Some think we should maintain a file where the subscriber is allowed to record their comments / side of the events vs actually changing our files.  (Like the Credit Card Companies do, when the post the card holder's side of the story).  Would we have to have flags that further restrict (beyond normal HIPAA rules) who we would disclose the transaction data to if the member requested that we delete the information?     Another group says we should actually change history files.  If we truly change or delete data that we've acted upon, what are the implications to back end financial reporting (i.e. 1099’s, data previously reported doesn’t balance to current data, we can't substantiate a cost plus bill, etc).  For example, what happens if the member tells us, I told the doctor that he wasn't supposed to submit that claim to you for payment...  I want you to delete the claim!  (real example... appropriately de-identified... :-)).  I can just see the IRS saying, what do you mean you didn't report a payment to a doctor just because the member requested that the claim be deleted!     For either scenario, what about the data that we've already disclosed, before we received the "amendment" request to delete the data?  Do we have to follow the data with the requested changes?     Are there any other payers that have or are confronting this issue?   Jim       Jim Moores - HIPAA Team Leader - Privacy Antares Management Solutions 23700 Commerce Park Road Beachwood, Ohio   44122-5832   [EMAIL PROTECTED] Phone: (216)292-1605 Fax:      (216)292-1619   ********************************************************************** To be removed from this list, go to: http://snip.wedi.org/unsubscribe.cfm?list=privacy and enter your email address. ------------------------------------------------------------------------------ CONFIDENTIALITY NOTICE: This message is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that you are strictly prohibited from printing, storing, disseminating, distributing or copying this communication. If you have received this communication in error, please notify us immediately by replying to the message and deleting it from your computer. Thank You, Antares Management Solutions. ==============================================================================