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
**********************************************************************
To be removed from this list, go to:
http://snip.wedi.org/unsubscribe.cfm?list=ivacy
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.
==============================================================================
