RE: Filing deadline for complaints

2003-03-14 Thread CBowman
Diane,

If you limit your complaint acceptance period to 30 days, the only other
recourse the person would have is to file a complaint with the Secretary if
the occurance is more than 30 days old.  For my agency, I had rather our
patients come to us with a complaint rather than the Secretary of DHHS, so I
am leaving the door open to accepting complaints.  


Cindi Bowman
Quality and Compliance Coordinator
Catawba County Health Department
828-695-5847


-Original Message-
From: Diana DeWeese [mailto:[EMAIL PROTECTED]
Sent: Thursday, March 13, 2003 3:29 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Filing deadline for complaints


Regarding complaints filed with the Secretary of DHHS, the Privacy Rule
states in 160.306 (b)(3) that a complaint must be filed within 180 days of
when the complainant knew or should have known.

Can a covered entity specify a shorter time frame for an individual filing a
complaint with the covered entity - such as - within 30 days?




Diana DeWeese
Illinois Dept of Human Services
[EMAIL PROTECTED]
217-557-9103


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BA with Nursing Homes

2003-03-14 Thread Mitch Kwiatkowski
We have several doctors within our primary care group that also work as
independent contractors with nursing homes to fill the role of medical
director.  By rule, the medical director has to visit with each patient of
the nursing home whether he/she is a patient of that doctor or not.  The
doctor does not actually treat a person unless he/she is a patient of that
doctor, but he does see the all of the patients' records and is therefore
exposed to their PHI.  My question is, do we need a BAA with those nursing
homes since our doctors are seeing PHI of non-patients, and it is not for
treatment purposes?  These physicians, while working as independent
contractors, have an agreement with the rest of the primary care group in
regards to contracting out that ultimately means that the BAA would be with
the group, not the individual physicians.  Our question is whether there
needs to be a BAA at all because of this scenario.

Regards,

Mitch Kwiatkowski
IS/IT Manager
Preferred Primary Care Physicians


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RE: A tricky BA Questions

2003-03-14 Thread Deborah Campbell
Title: RE: A tricky BA Questions





1) If it is part of the payors Quality Assurance, the payor is allowed to audit a providers records as long as both the payor and the provider have a relationship with the patient. I don't have the citation in front of me, but I can find it. It is listed, in the 8/14/02 revisions, under Use and Disclosure of PHI. If the payor has a BA Agreement with an auditor, the auditor has a right to look at anything the payor has would have a right to look at.

2) The payor would not be a BA of the provider. In order to be a BA the payor would need to be using and disclosing PHI on behalf of the provider. They are not doing that. They are using and disclosing PHI on their own behalf.

Just my opinion.
Deborah Campbell
Compliance Coordinator


Dominion Dental Services, Inc.
115 South Union Street, Suite 300
Alexandria, Virginia 22314


Phn: (703) 518-5000 ext. 3035
Fax: (703) 518-8849
Toll Free: 888-518-5338
Email: [EMAIL PROTECTED]


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-Original Message-
From: Vikas Budhiraja [mailto:[EMAIL PROTECTED]]
Sent: Thursday, March 13, 2003 4:05 PM
To: WEDI SNIP Privacy Workgroup List
Subject: A tricky BA Questions



I have been encountered with a tricky BA question and hope someone can
provide some insight.


Insurance companies engage certain agencies to audit provider records to
verify if what the hospital billed was correct and if the insurance company
has overpaid. Since these audit agencies are engaged by the Insurance
Companies they will be the BA of the Insurance companies. However, they are
going to a provider facility to verify the records, My questions are:
1. Are they allowed to do this under the HIPAA law? If yes, what type of
relationship will they have with the provider?
2. If a payer engages an agency to audit provider records does the payer
become the BA of the provider?


Regards,
Vikas




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Re: Filing deadline for complaints

2003-03-14 Thread Doug Webb



Amen, Cindi!

The opinions expressed here are my own and not necessarily the opinion of 
LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary 
Hospital  Health Care Centers[EMAIL PROTECTED]

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  - Original Message - 
  From: 
  [EMAIL PROTECTED] 
  
  To: WEDI SNIP Privacy Workgroup List 
  
  Sent: Friday, March 14, 2003 07:30 
  AM
  Subject: RE: Filing deadline for 
  complaints
  Diane,If you limit your complaint acceptance period to 
  30 days, the only otherrecourse the person would have is to file a 
  complaint with the Secretary ifthe occurance is more than 30 days 
  old. For my agency, I had rather ourpatients come to us with a 
  complaint rather than the Secretary of DHHS, so Iam leaving the door open 
  to accepting complaints. Cindi BowmanQuality and 
  Compliance CoordinatorCatawba County Health 
  Department828-695-5847-Original Message-From: 
  Diana DeWeese [mailto:[EMAIL PROTECTED]Sent: Thursday, March 13, 
  2003 3:29 PMTo: WEDI SNIP Privacy Workgroup ListSubject: Filing 
  deadline for complaintsRegarding complaints filed with the 
  Secretary of DHHS, the Privacy Rulestates in 160.306 (b)(3) that a 
  complaint must be filed within 180 days ofwhen the complainant knew or 
  should have known.Can a covered entity specify a shorter time 
  frame for an individual filing acomplaint with the covered entity - such 
  as - within 30 days?Diana DeWeeseIllinois Dept of 
  Human Services[EMAIL PROTECTED]217-557-9103---The 
  WEDI SNIP listserv to which you are subscribed is not moderated. 
  Thediscussions on this listserv therefore represent the views of the 
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  WEDI Boardof Directors nor WEDI SNIP. If you wish to receive an official 
  opinion, postyour question to the WEDI SNIP Issues Database athttp://snip.wedi.org/tracking/. 
  These listservs should not be used forcommercial marketing purposes or 
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NPP type size?

2003-03-14 Thread Beth Cole
I've seen several references on various mailing lists to something said 
at one of the OCR regional conferences regarding the mandated font size 
of the NPP.   What I'm seeing indicates that attendees at the conference 
were told that in order to comply with other Medicare regulations, the 
type size had to be no less than 12 point.

If we take it to 12 point, our NPP is at 8 pages.  If we put it at 
either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

Can anyone give me a black-letter law or regulation citation on this, or 
was this someone talking at a conference who didn't know what he was 
talking about?

Thanks!

Beth

--
Beth Cole
Information Services Support Specialist
Newman Regional Health
Emporia, Kansas


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Re: NPP type size?

2003-03-14 Thread William J. Kammerer
You can't prove a negative - I don't believe the Privacy Rule mandates
any particular font size.

9 point is really the smallest human-readable size. 12 point is the
standard at which most folks feel comfortable. 10 point is the absolute
minimum to be taken seriously, though it touches on the preferred size
used in crazy right-wing lunatic screeds (not that I read any of that
stuff, mind you). Unless you're intending to deceive - or hide
something - I would consider a smaller font size unadvisable.

Consider the geriatric crowd in your choice of font. You don't have to
be a senior curmudgeon to be annoyed at tricks and stunts hidden in
teensy font. Shorten your NPP instead, because 8 pages are well beyond
most folks' attention span, anyway - and clearly makes the document
pointless. Keep in mind that executives can't read much beyond one
paragraph with four bulleted points, unless it's some big font book
about Jack Welch sharing his leadership methods.

William J. Kammerer
Novannet, LLC.
Columbus, US-OH 43221-3859
+1 (614) 487-0320

- Original Message -
From: Beth Cole [EMAIL PROTECTED]
To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED]
Sent: Friday, 14 March, 2003 10:23 AM
Subject: NPP type size?


I've seen several references on various mailing lists to something said
at one of the OCR regional conferences regarding the mandated font size
of the NPP.   What I'm seeing indicates that attendees at the conference
were told that in order to comply with other Medicare regulations, the
type size had to be no less than 12 point.

If we take it to 12 point, our NPP is at 8 pages.  If we put it at
either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

Can anyone give me a black-letter law or regulation citation on this, or
was this someone talking at a conference who didn't know what he was
talking about?

Thanks!

Beth

--
Beth Cole
Information Services Support Specialist
Newman Regional Health
Emporia, Kansas


---
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RE: NPP type size?

2003-03-14 Thread Sherry Neuman
Please reply to all.




-Original Message-
From: Beth Cole [mailto:[EMAIL PROTECTED] 
Sent: Friday, March 14, 2003 7:23 AM
To: WEDI SNIP Privacy Workgroup List
Subject: NPP type size?


I've seen several references on various mailing lists to something said 
at one of the OCR regional conferences regarding the mandated font size 
of the NPP.   What I'm seeing indicates that attendees at the conference 
were told that in order to comply with other Medicare regulations, the 
type size had to be no less than 12 point.

If we take it to 12 point, our NPP is at 8 pages.  If we put it at 
either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

Can anyone give me a black-letter law or regulation citation on this, or 
was this someone talking at a conference who didn't know what he was 
talking about?

Thanks!

Beth

-- 
Beth Cole
Information Services Support Specialist
Newman Regional Health
Emporia, Kansas



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RE: NPP type size?

2003-03-14 Thread Musser, Marilyn J
Hi- the body type for our NOPP is 10 pt - see it on our web site:
http://www.wellmark.com/e_business/pdf/T-2601.pdf



Marilyn Musser
Provider Relations Manager
HIPAA-AS Communications Office
Wellmark, Inc.
phone: 515.248.5588
fax: 515.245.4620
[EMAIL PROTECTED]

 -Original Message-
From:   Sherry Neuman [mailto:[EMAIL PROTECTED] 
Sent:   Friday, March 14, 2003 10:55 AM
To: WEDI SNIP Privacy Workgroup List
Subject:RE: NPP type size?

Please reply to all.




-Original Message-
From: Beth Cole [mailto:[EMAIL PROTECTED] 
Sent: Friday, March 14, 2003 7:23 AM
To: WEDI SNIP Privacy Workgroup List
Subject: NPP type size?


I've seen several references on various mailing lists to something said 
at one of the OCR regional conferences regarding the mandated font size 
of the NPP.   What I'm seeing indicates that attendees at the conference 
were told that in order to comply with other Medicare regulations, the 
type size had to be no less than 12 point.

If we take it to 12 point, our NPP is at 8 pages.  If we put it at 
either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

Can anyone give me a black-letter law or regulation citation on this, or 
was this someone talking at a conference who didn't know what he was 
talking about?

Thanks!

Beth

-- 
Beth Cole
Information Services Support Specialist
Newman Regional Health
Emporia, Kansas



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participants, and do not necessarily represent the views of the WEDI Board
of Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.   These listservs should not be used for
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commercial marketing purposes or discussion of specific vendor products and services.  
They also are not intended to be used as a forum for personal disagreements or 
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RE: NPP type size?

2003-03-14 Thread Patricia Conroe
I can't cite the documentation specifically, but I have been informed by other 
coworkers that Medicare does require a 12 font.  I believe it's for the beneficiary 
notices.  So, although HIPAA does not state you must use a certain font, will you get 
in trouble by Medicare if you don't use 12?  Who knows.

 Musser, Marilyn J [EMAIL PROTECTED] 03/14/03 01:16PM 
Hi- the body type for our NOPP is 10 pt - see it on our web site:
http://www.wellmark.com/e_business/pdf/T-2601.pdf 



Marilyn Musser
Provider Relations Manager
HIPAA-AS Communications Office
Wellmark, Inc.
phone: 515.248.5588
fax: 515.245.4620
[EMAIL PROTECTED] 

 -Original Message-
From:   Sherry Neuman [mailto:[EMAIL PROTECTED] 
Sent:   Friday, March 14, 2003 10:55 AM
To: WEDI SNIP Privacy Workgroup List
Subject:RE: NPP type size?

Please reply to all.




-Original Message-
From: Beth Cole [mailto:[EMAIL PROTECTED] 
Sent: Friday, March 14, 2003 7:23 AM
To: WEDI SNIP Privacy Workgroup List
Subject: NPP type size?


I've seen several references on various mailing lists to something said 
at one of the OCR regional conferences regarding the mandated font size 
of the NPP.   What I'm seeing indicates that attendees at the conference 
were told that in order to comply with other Medicare regulations, the 
type size had to be no less than 12 point.

If we take it to 12 point, our NPP is at 8 pages.  If we put it at 
either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

Can anyone give me a black-letter law or regulation citation on this, or 
was this someone talking at a conference who didn't know what he was 
talking about?

Thanks!

Beth

-- 
Beth Cole
Information Services Support Specialist
Newman Regional Health
Emporia, Kansas



---
The WEDI SNIP listserv to which you are subscribed is not moderated. The
discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board
of Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.   These listservs should not be used for
commercial marketing purposes or discussion of specific vendor products and
services.  They also are not intended to be used as a forum for personal
disagreements or unprofessional communication at any time.

You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To
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Re: Self insured health plans NPP

2003-03-14 Thread Sue Ryan
John,

Thank you for your prompt and thorough response.  You helped clarify and
validate what I thought was correct.

The company that I made reference is a BA, not a CE.  The BA does have an
employee onsite that acts as a liaison between the PEO and the company for
most of the HR functions.  This includes assisting with enrollment functions
AND, until our review, assisting employees with their health claim problems.
Since their health benefits were put up for bid, the enrollment forms
included a medical history questionnaire. This questionnaire was collected
by the liaison and forwarded to the PEO as part of the enrollment forms.
However, a copy was also maintained onsite.  The end result was that their
medical benefits changed from a self-insured GHP to a fully insured plan for
medical but their dental GHP was going to remain self-insured.

One of our recommendations to this company was to reassess, i.e., risk
assess, whether the company wanted the liaison to continue with providing
this level of assistance to its employees and thereby requiring changes to
their SPD and a greater responsibility under the Privacy Rule.  Per our
feedback, they chose not to.  Additionally, we recommended to the company
that the liaison separate the personnel file documents from any GHP
documents and to destroy the copies of the questionnaires.

As to your question, interestingly, the PEO had made no contact with this
company in regard to a BA agreement, assessing the functions the liaison was
performing, what the PEO was expecting to do as far as issuing the NPP
(since dental is still self-insured) or HIPAA training in general.

What I have found is that not everything is what you think it is when you
approach each type of entity (CE, BA, or Employer).  There are always twists
and turns and surprises that need to be considered in each particular
situation.  Sue

Confidentiality Notice: This email message, includng any attachments, is for
the sole use of the intended recipient(s) and may contain confidential and
privileged information.  Any unauthorized review, use, disclosure or
distribution is prohibited.  If you are not the intended recipient, please
contact Hazen Group, Inc. at (317) 849-6065 and destroy all copies of the
original message.

Sue Ryan, RN, MPS
Consultant
Hazen Group, Inc.
Phone: (315) 468-2603
Fax: (315) 487-0153

- Original Message -
From: John J. D'Amato [EMAIL PROTECTED]
To: Sue Ryan [EMAIL PROTECTED]; WEDI SNIP Privacy Workgroup List
[EMAIL PROTECTED]
Sent: Thursday, March 13, 2003 10:20 PM
Subject: Re: Self insured health plans  NPP


 Hi, Sue.

 What I meant by my comment is that a group health plan's relationship to a
 health insurance issuer and its relationship to a TPA are associated with
 radically different legal responsibilities under the Privacy Rule, even
 where the two relationships are functionally equivalent.  This is
sometimes
 disconcerting to self-insuring clients who believe that by contracting out
 functions to a TPA, they ought to be relieved of responsibilities under
the
 Privacy Rule.

 But you have raised a different fact pattern.  I take it that you are
 referring to the situation in which an employer contracts with an employee
 leasing or similar company.  In such a situation, the recipient of the
 services of the employees (your organization) is not the employer of
record,
 and the leased employees receive benefits under plans sponsored and
 maintained by the leasing company, not by the recipient of the services.

 If that is your situation, then I would agree with you that the plan
sponsor
 is not your company, but the leasing company, and the Privacy Rule burdens
 fall on that company and its group health plan, not on your company.
Those
 burdens would include providing or maintaining an NPP (to the extent that
 benefits are self-insured or the PEO receives or creates PHI beyond
summary
 health or enrollment information).

 Nevertheless, I think you should think carefully about how the Privacy
Rule
 may affect your company.  Are there individuals who are employed by your
 company (not the PEO) and who deal with the PEO regarding health plan
 matters?  If so, then those individuals will be members of the health
plan's
 workforce (even though they are your employees) and will require Privacy
 Rule training, etc.

 In particular, if your company (or the PEO) sponsors an EAP, consider how
 the flow of information works from management personnel in your company to
 the EAP and back.  You will want to insure that safeguards are in place
with
 respect to the confidentiality of this information and to make sure that
you
 (or the PEO, if it is a PEO plan) obtain whatever authorizations will be
 required to monitor the satisfactory completion of treatment by an
 individual referred to EAP.

 Out of curiosity, is the PEO requiring your company to enter into a BA
 agreement with it?

 Hope this helps.
 John
 redhipaa.com (coming soon)

  John,
 
  In your explanation, you state 

RE: NPP type size?

2003-03-14 Thread DCampbell
Would anyone know if there is a requirement as to the type of mailing that must be 
used?  I thought I had read that it must be first class mail only.  

Your help is greatly appreciated.

Darlene Campbell
SAMBA Insurance
[EMAIL PROTECTED]

-Original Message-
From: Sherry Neuman [mailto:[EMAIL PROTECTED]
Sent: Friday, March 14, 2003 1:29 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: NPP type size?


This question was asked recently, and the answer was that in California the
type size must be 12 pt.

Also:
From the final Privacy Regulation Preamble:

Plain Language

As in the proposed rule, we require the notice to be written in plain
language. A covered entity can satisfy the plain language requirement if it
makes a reasonable effort to: organize material to serve the needs of the
reader; write short sentences in the active voice, using ``you'' and other
pronouns; use common, everyday words in sentences; and divide material into
short sections.

[[Page 82549]]

We do not require particular formatting specifications, such as
easy-to-read design features (e.g., lists, tables, graphics, contrasting
colors, and white space), TYPE FACE, AND FONT SIZE. However, the purpose of
the notice is to inform the recipients about their rights and how protected
health information collected about them may be used or disclosed. Recipients
who cannot understand the covered entity's notice will miss important
information about their rights under this rule and about how the covered
entity is protecting health information about them. One of the goals of this
rule is to create an environment of open communication and transparency with
respect to the use and disclosure of protected health information. A lack of
clarity in the notice could undermine this goal and create
misunderstandings. Covered entities have an incentive to make their notice
statements clear and concise. We believe that the more understandable the
notice is, the more confidence the public will have in the covered entity's
commitment to protecting the privacy of health information

and

Comment: We received many comments on the model notice provided in the
proposed ruleA few commenters recommended specific formatting
requirements, such as FONT SIZE OR TYPE.

Response: On the whole, we found commenters' arguments for flexibility
in the regulation more persuasive than those arguing for more
standardization. We agree that a uniform notice would not capture the wide
variation in information practices across covered entities. We therefore do
not include a model notice in the final rule, and do not require inclusion
of specific language in the notice (except for a standard header). We also
do not require particular formatting. We do, however, require the notice to
be written in plain language. (See above for guidance on writing documents
in plain language.) We also agree with commenters that the notice should
contain a standard header to draw the individual's attention to the notice
and facilitate the individual's ability to recognize the notice across
covered entities (emphases added)





-Original Message-
From: Musser, Marilyn J [mailto:[EMAIL PROTECTED] 
Sent: Friday, March 14, 2003 10:16 AM
To: Sherry Neuman; WEDI SNIP Privacy Workgroup List
Subject: RE: NPP type size?


Hi- the body type for our NOPP is 10 pt - see it on our web site:
http://www.wellmark.com/e_business/pdf/T-2601.pdf



Marilyn Musser
Provider Relations Manager
HIPAA-AS Communications Office
Wellmark, Inc.
phone: 515.248.5588
fax: 515.245.4620
[EMAIL PROTECTED]

 -Original Message-
From:   Sherry Neuman [mailto:[EMAIL PROTECTED] 
Sent:   Friday, March 14, 2003 10:55 AM
To: WEDI SNIP Privacy Workgroup List
Subject:RE: NPP type size?

Please reply to all.




-Original Message-
From: Beth Cole [mailto:[EMAIL PROTECTED] 
Sent: Friday, March 14, 2003 7:23 AM
To: WEDI SNIP Privacy Workgroup List
Subject: NPP type size?


I've seen several references on various mailing lists to something said 
at one of the OCR regional conferences regarding the mandated font size 
of the NPP.   What I'm seeing indicates that attendees at the conference 
were told that in order to comply with other Medicare regulations, the 
type size had to be no less than 12 point.

If we take it to 12 point, our NPP is at 8 pages.  If we put it at 
either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

Can anyone give me a black-letter law or regulation citation on this, or 
was this someone talking at a conference who didn't know what he was 
talking about?

Thanks!

Beth

-- 
Beth Cole
Information Services Support Specialist
Newman Regional Health
Emporia, Kansas



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Re: NPP type size?

2003-03-14 Thread Ellen Rubin
When this HIPAA preparation is over someone should write a book - I
nominate William.  Ellen Rubin

Ellen Rubin, RN, BSN
Privacy Coordinator
Box 359738
Harborview Medical Center
Office:   206 731-6048
Fax:  206 731-2097
Page:206 989-1276
___
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Privileged/Confidential Information may be contained in this message.  You
may not copy or deliver this message to anyone.  If you are not the
addressee indicated in this message, you should destroy it and notify the
sender by reply email.



- Original Message -
From: William J. Kammerer [EMAIL PROTECTED]
To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED]
Sent: Friday, March 14, 2003 8:32 AM
Subject: Re: NPP type size?


 You can't prove a negative - I don't believe the Privacy Rule mandates
 any particular font size.

 9 point is really the smallest human-readable size. 12 point is the
 standard at which most folks feel comfortable. 10 point is the absolute
 minimum to be taken seriously, though it touches on the preferred size
 used in crazy right-wing lunatic screeds (not that I read any of that
 stuff, mind you). Unless you're intending to deceive - or hide
 something - I would consider a smaller font size unadvisable.

 Consider the geriatric crowd in your choice of font. You don't have to
 be a senior curmudgeon to be annoyed at tricks and stunts hidden in
 teensy font. Shorten your NPP instead, because 8 pages are well beyond
 most folks' attention span, anyway - and clearly makes the document
 pointless. Keep in mind that executives can't read much beyond one
 paragraph with four bulleted points, unless it's some big font book
 about Jack Welch sharing his leadership methods.

 William J. Kammerer
 Novannet, LLC.
 Columbus, US-OH 43221-3859
 +1 (614) 487-0320

 - Original Message -
 From: Beth Cole [EMAIL PROTECTED]
 To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED]
 Sent: Friday, 14 March, 2003 10:23 AM
 Subject: NPP type size?


 I've seen several references on various mailing lists to something said
 at one of the OCR regional conferences regarding the mandated font size
 of the NPP.   What I'm seeing indicates that attendees at the conference
 were told that in order to comply with other Medicare regulations, the
 type size had to be no less than 12 point.

 If we take it to 12 point, our NPP is at 8 pages.  If we put it at
 either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

 Can anyone give me a black-letter law or regulation citation on this, or
 was this someone talking at a conference who didn't know what he was
 talking about?

 Thanks!

 Beth

 --
 Beth Cole
 Information Services Support Specialist
 Newman Regional Health
 Emporia, Kansas


 ---
 The WEDI SNIP listserv to which you are subscribed is not moderated. The
discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board
of Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.   These listservs should not be used for
commercial marketing purposes or discussion of specific vendor products and
services.  They also are not intended to be used as a forum for personal
disagreements or unprofessional communication at any time.

 You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED]
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you wish to receive an official opinion, post your question to the WEDI SNIP Issues 
Database at http://snip.wedi.org/tracking/.   These listservs should not be used for 
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They also are not intended to be used as a forum for personal disagreements or 
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RE: NPP type size?

2003-03-14 Thread Art Schenkman
I second the motion.  All in favor say Aye  (please
don't reply, just kidding)

-Original Message-
From: Ellen Rubin [mailto:[EMAIL PROTECTED]
Sent: Friday, March 14, 2003 1:46 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: NPP type size?


When this HIPAA preparation is over someone should write a book - I
nominate William.  Ellen Rubin

Ellen Rubin, RN, BSN
Privacy Coordinator
Box 359738
Harborview Medical Center
Office:   206 731-6048
Fax:  206 731-2097
Page:206 989-1276
___
Email Confidentiality Footer
Privileged/Confidential Information may be contained in this message.  You
may not copy or deliver this message to anyone.  If you are not the
addressee indicated in this message, you should destroy it and notify the
sender by reply email.



- Original Message -
From: William J. Kammerer [EMAIL PROTECTED]
To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED]
Sent: Friday, March 14, 2003 8:32 AM
Subject: Re: NPP type size?


 You can't prove a negative - I don't believe the Privacy Rule mandates
 any particular font size.

 9 point is really the smallest human-readable size. 12 point is the
 standard at which most folks feel comfortable. 10 point is the absolute
 minimum to be taken seriously, though it touches on the preferred size
 used in crazy right-wing lunatic screeds (not that I read any of that
 stuff, mind you). Unless you're intending to deceive - or hide
 something - I would consider a smaller font size unadvisable.

 Consider the geriatric crowd in your choice of font. You don't have to
 be a senior curmudgeon to be annoyed at tricks and stunts hidden in
 teensy font. Shorten your NPP instead, because 8 pages are well beyond
 most folks' attention span, anyway - and clearly makes the document
 pointless. Keep in mind that executives can't read much beyond one
 paragraph with four bulleted points, unless it's some big font book
 about Jack Welch sharing his leadership methods.

 William J. Kammerer
 Novannet, LLC.
 Columbus, US-OH 43221-3859
 +1 (614) 487-0320

 - Original Message -
 From: Beth Cole [EMAIL PROTECTED]
 To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED]
 Sent: Friday, 14 March, 2003 10:23 AM
 Subject: NPP type size?


 I've seen several references on various mailing lists to something said
 at one of the OCR regional conferences regarding the mandated font size
 of the NPP.   What I'm seeing indicates that attendees at the conference
 were told that in order to comply with other Medicare regulations, the
 type size had to be no less than 12 point.

 If we take it to 12 point, our NPP is at 8 pages.  If we put it at
 either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

 Can anyone give me a black-letter law or regulation citation on this, or
 was this someone talking at a conference who didn't know what he was
 talking about?

 Thanks!

 Beth

 --
 Beth Cole
 Information Services Support Specialist
 Newman Regional Health
 Emporia, Kansas


 ---
 The WEDI SNIP listserv to which you are subscribed is not moderated. The
discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board
of Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.   These listservs should not be used for
commercial marketing purposes or discussion of specific vendor products and
services.  They also are not intended to be used as a forum for personal
disagreements or unprofessional communication at any time.

 You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED]
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your question to the WEDI SNIP Issues Database at
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If you need to unsubscribe but your 

optical lab as health care provider

2003-03-14 Thread Laura Schmitt








Im looking for thoughts on whether an optical lab is
a health care provider subject to the HIPAA privacy rule. My thinking is
that while it seems a stretch to include a lab that fills orders for glasses
and has PHI in the way of prescriptions for such glasses, the definitions of
health care provider would reach the lab and they would be included in the rule
if order information and requests for payment are communicated electronically
between the lab and the doctors office. If someone has any
authority which would take the lab out of the definition of health care
provider, I would appreciate hearing it.



Laura D. Schmitt

[EMAIL PROTECTED]

712-277-4561



This electronic message and any attachments hereto contain
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Hartnett, Storm  Jensen, P.C., which may be privileged, confidential, or
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for the addressee only. If you are not the addressee, any disclosure,
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RE: NPP type size?

2003-03-14 Thread Karen Williamson
I just want someone to tell me when it's over!

Karen Williamson
Lead System Project Manager
El Paso County Dept. of Health and Environment, CO
719 575-8468 

-Original Message-
From: Art Schenkman [mailto:[EMAIL PROTECTED]
Sent: Friday, March 14, 2003 1:57 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: NPP type size?


I second the motion.  All in favor say Aye  (please
don't reply, just kidding)

-Original Message-
From: Ellen Rubin [mailto:[EMAIL PROTECTED]
Sent: Friday, March 14, 2003 1:46 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: NPP type size?


When this HIPAA preparation is over someone should write a book - I
nominate William.  Ellen Rubin

Ellen Rubin, RN, BSN
Privacy Coordinator
Box 359738
Harborview Medical Center
Office:   206 731-6048
Fax:  206 731-2097
Page:206 989-1276
___
Email Confidentiality Footer
Privileged/Confidential Information may be contained in this message.  You
may not copy or deliver this message to anyone.  If you are not the
addressee indicated in this message, you should destroy it and notify the
sender by reply email.



- Original Message -
From: William J. Kammerer [EMAIL PROTECTED]
To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED]
Sent: Friday, March 14, 2003 8:32 AM
Subject: Re: NPP type size?


 You can't prove a negative - I don't believe the Privacy Rule mandates
 any particular font size.

 9 point is really the smallest human-readable size. 12 point is the
 standard at which most folks feel comfortable. 10 point is the absolute
 minimum to be taken seriously, though it touches on the preferred size
 used in crazy right-wing lunatic screeds (not that I read any of that
 stuff, mind you). Unless you're intending to deceive - or hide
 something - I would consider a smaller font size unadvisable.

 Consider the geriatric crowd in your choice of font. You don't have to
 be a senior curmudgeon to be annoyed at tricks and stunts hidden in
 teensy font. Shorten your NPP instead, because 8 pages are well beyond
 most folks' attention span, anyway - and clearly makes the document
 pointless. Keep in mind that executives can't read much beyond one
 paragraph with four bulleted points, unless it's some big font book
 about Jack Welch sharing his leadership methods.

 William J. Kammerer
 Novannet, LLC.
 Columbus, US-OH 43221-3859
 +1 (614) 487-0320

 - Original Message -
 From: Beth Cole [EMAIL PROTECTED]
 To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED]
 Sent: Friday, 14 March, 2003 10:23 AM
 Subject: NPP type size?


 I've seen several references on various mailing lists to something said
 at one of the OCR regional conferences regarding the mandated font size
 of the NPP.   What I'm seeing indicates that attendees at the conference
 were told that in order to comply with other Medicare regulations, the
 type size had to be no less than 12 point.

 If we take it to 12 point, our NPP is at 8 pages.  If we put it at
 either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

 Can anyone give me a black-letter law or regulation citation on this, or
 was this someone talking at a conference who didn't know what he was
 talking about?

 Thanks!

 Beth

 --
 Beth Cole
 Information Services Support Specialist
 Newman Regional Health
 Emporia, Kansas


 ---
 The WEDI SNIP listserv to which you are subscribed is not moderated. The
discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board
of Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.   These listservs should not be used for
commercial marketing purposes or discussion of specific vendor products and
services.  They also are not intended to be used as a forum for personal
disagreements or unprofessional communication at any time.

 You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED]
 To unsubscribe from this list, go to the Subscribe/Unsubscribe form at
http://subscribe.wedi.org or send a blank email to
[EMAIL PROTECTED]
 If you need to unsubscribe but your current email address is not the same
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form at http://subscribe.wedi.org



---
The WEDI SNIP listserv to which you are subscribed is not moderated. The
discussions on this listserv therefore represent the views of the individual
participants, and do not necessarily represent the views of the WEDI Board
of Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.   These listservs should not be used for
commercial marketing purposes or discussion of specific vendor products and
services.  They also are not intended to 

RE: NPP type size?

2003-03-14 Thread Marcia Meinert
Maybe you can get by having the official NPP in 10 Font.  Have it state
that there is a large print NPP available upon request.   It wouldn't be
as expensive as having them all made in a larger font.  But it would
certainly accomodate those few patients who may need it a little bit bigger.

-Original Message-
From: Patricia Conroe [mailto:[EMAIL PROTECTED]
Sent: Friday, March 14, 2003 1:06 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: NPP type size?


I can't cite the documentation specifically, but I have been informed by
other coworkers that Medicare does require a 12 font.  I believe it's for
the beneficiary notices.  So, although HIPAA does not state you must use a
certain font, will you get in trouble by Medicare if you don't use 12?  Who
knows.

 Musser, Marilyn J [EMAIL PROTECTED] 03/14/03 01:16PM 
Hi- the body type for our NOPP is 10 pt - see it on our web site:
http://www.wellmark.com/e_business/pdf/T-2601.pdf



Marilyn Musser
Provider Relations Manager
HIPAA-AS Communications Office
Wellmark, Inc.
phone: 515.248.5588
fax: 515.245.4620
[EMAIL PROTECTED]

 -Original Message-
From:   Sherry Neuman [mailto:[EMAIL PROTECTED]
Sent:   Friday, March 14, 2003 10:55 AM
To: WEDI SNIP Privacy Workgroup List
Subject:RE: NPP type size?

Please reply to all.




-Original Message-
From: Beth Cole [mailto:[EMAIL PROTECTED]
Sent: Friday, March 14, 2003 7:23 AM
To: WEDI SNIP Privacy Workgroup List
Subject: NPP type size?


I've seen several references on various mailing lists to something said
at one of the OCR regional conferences regarding the mandated font size
of the NPP.   What I'm seeing indicates that attendees at the conference
were told that in order to comply with other Medicare regulations, the
type size had to be no less than 12 point.

If we take it to 12 point, our NPP is at 8 pages.  If we put it at
either 9 or 10 point, it's a 4.  So, this is slightly worrisome to us.

Can anyone give me a black-letter law or regulation citation on this, or
was this someone talking at a conference who didn't know what he was
talking about?

Thanks!

Beth

--
Beth Cole
Information Services Support Specialist
Newman Regional Health
Emporia, Kansas



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The WEDI SNIP listserv to which you are subscribed is not moderated. The
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of Directors nor WEDI SNIP. If you wish to receive an official opinion, post
your question to the WEDI SNIP Issues Database at
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To 

Displaying Data in web browser……. Indefinitely….

2003-03-14 Thread Hipaa Learner

We developed a web based application where in patient data get displayed in end user browser. User ID is required to log in to web site and it uses HTTPS to login. My question is, some one logs in,….view the data….. walks away from computer. Since he has not logged out from our website, patient sensitive data is still displayed on his computer. Does it a violation of HIPAA security rule ?thanks for your suggestion.
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