To any one on the listserv who works for a Health Plan that has or is going through NCQA accreditation under the 2001 Standards: We are going through our review in September of this year. Standard RR5 is essentially a major part of HIPAA privacy regulation. Standard RR5 has pulled many of the HIPAA privacy requirements together and called them the NCQA privacy guidelines. We are in good shape for implementing almost all of the NCQA requirements for Privacy except one of them, RR5.6 which NCQA calls "Special Consents." NCQA says we need a policy that covers special consents from members who have sensitive conditions, like HIV/Aids, if we need to use or disclose any PHI on those members. We feel our policy on Authorizations (as HIPAA calls them) covers this requirement, but the mock reviewer we had says it has to be a completely separate policy. If anyone else out there is being reviewed for these same 2001 standards, would you mind sharing your policy? We are not happy with any drafts we've been able to come up with (and we have made sure to research our state laws on sensitive medical conditions, - that avenue didn't help us much.)
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