What PHI to give out to callers?
What kind of policies are offices developing for disclosing patient health information to people over the phone, when patients and people other than the patient, call for example? Thanks again. Jill Rubin, Esq. (617)388-2404 [EMAIL PROTECTED] --- 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: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
Re: Medical Records
There are specific requirements in state laws that say what happens when a practice closes. I wish I could give you a direct reference, but I can't. I believe that PA law says you must post a notice at the office and in the newspaper informing patients of the closure and tell them how they can obtain their records if they want to. I'm not sure how long the notice must be posted and for how long the records must be stored somewhere in this instance. Patients can be given their original medical records in this case as well as far as I know. Please someone out there feel free to correct me. Cathy Campbell [EMAIL PROTECTED] 01/28/03 02:48PM I have an interesting question that I need some help with. We had an office manager call today inquiring about a problem that I don't know how to respond to her. She is in a practice where a physician shared expenses and leased space from her practice (he was his own entity). The physician passed away over the weekend. They are unsure of what to do with the medical records. They do not belong to the practice, the belonged to the physician who passed away. Can the manager give the original charts to the patients? Thanks for any and all input! Cathy A. Campbell HIPAA Compliance Specialist Healthcare Compliance Group (317)575-1041 (800)816-1161 (317)575-1043 (fax) --- 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe 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 be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
Re: Any HIPAA Humor tools out there?
Title: Message Some of this stuff sure looks funny to me. :) Ken Steen Apollo - Original Message - From: Brett Hacker To: WEDI SNIP Privacy Workgroup List Sent: Wednesday, January 29, 2003 6:37 AM Subject: RE: Any HIPAA Humor tools out there? I don't know anything about HIPAA humor, but everyone should relax regarding the rumor I heard yesterday out of Washington: it was a HIPPO that died over the weekend at the National Zoo in Washington, not HIPAA. -Original Message-From: Bentz-Miller, Judith [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 8:17 AMTo: WEDI SNIP Privacy Workgroup ListSubject: Any HIPAA Humor tools out there? does anyone have any good HIPAA humor training tools that they would be willing to share? I am doing a presentation later today and I am looking for something different. Email me directly if you wish. Thank you for helping!---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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org This e-mail message or fax transmission and any attachment contains confidentialinformation that may be legally privileged. If you are not the intended recipient, you must notreview, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or anyattachments to it.If you have received this e-mail or fax in error, please immediately notifyus by return e-mail or by telephone at 501-223-3200 and delete this message.Please note thatif this e-mail message contains a forwarded message or is a reply to a prior message, some orall of the contents of this message or any attachments may not have been produced by Remettra, Inc.This notice is automatically appended to each e-mail or electronicallyproduced fax message leaving Remettra, Inc.Thank you. ---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 as the address subscribed to the list, please use the Subscribe/Unsubscribe 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 be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at
RE: Medical Records
Furthermore, any action of this nature should/would be the responsibility of the deceased physician's executor and not the practice. The practice appears not to own the med recs, etc. Rachel Foerster Principal Rachel Foerster Associates, Ltd. Professionals in Health Care EDI 39432 North Avenue Beach Park, IL 60099 Voice: 847-872-8070 Fax: 847-872-6860 eMail: [EMAIL PROTECTED] http://www.rfa-edi.com -Original Message- From: Patricia Conroe [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 7:43 AM To: WEDI SNIP Privacy Workgroup List Subject: Re: Medical Records There are specific requirements in state laws that say what happens when a practice closes. I wish I could give you a direct reference, but I can't. I believe that PA law says you must post a notice at the office and in the newspaper informing patients of the closure and tell them how they can obtain their records if they want to. I'm not sure how long the notice must be posted and for how long the records must be stored somewhere in this instance. Patients can be given their original medical records in this case as well as far as I know. Please someone out there feel free to correct me. Cathy Campbell [EMAIL PROTECTED] 01/28/03 02:48PM I have an interesting question that I need some help with. We had an office manager call today inquiring about a problem that I don't know how to respond to her. She is in a practice where a physician shared expenses and leased space from her practice (he was his own entity). The physician passed away over the weekend. They are unsure of what to do with the medical records. They do not belong to the practice, the belonged to the physician who passed away. Can the manager give the original charts to the patients? Thanks for any and all input! Cathy A. Campbell HIPAA Compliance Specialist Healthcare Compliance Group (317)575-1041 (800)816-1161 (317)575-1043 (fax) --- 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: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
Re: Any HIPAA Humor tools out there?
Get an acronym-matching contest going. Here's the first (and it's not original to me) Healthy Income Protection for Aggressive Attorneys F.W. (Bill) Danby, MD, Manchester, NH, USA - Original Message - From: Bentz-Miller, Judith To: WEDI SNIP Privacy Workgroup List Sent: Wednesday, January 29, 2003 9:17 AM Subject: Any HIPAA Humor tools out there? does anyone have any good HIPAA humor training tools that they would bewilling to share? I am doing a presentation later today and I am lookingfor something different. Email me directly if you wish. Thank you for helping!---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 as the address subscribed to the list, please use the Subscribe/Unsubscribe 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 be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
NPP revisions
164.520 [c][2][iv] Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision and promptly comply with the requirements of paragraph [c][2][iii] of this section, if applicable. I just want to run this by everyone, in our HIPAA committee meeting today we have decided to provide a NPP and get a signed acknowledgement of receipt with each admission to home care services, even if the patient was previously receiving services from our agency. The reasoning is, with the rapid turnover of our patients it would be extremely difficult to track which "edition" of our NPP a patient had received, and since our patients sometimes are re-admitted to our services years down the road it would allow us to make sure we had documentation thatthe NPP had been given. We may put a section on our acknowledgement form for the patient to check/sign if they are refusing a copy due to previous receipt. I think this should cover us pretty well . any cons to the plan? Traci Winter Hospitals Home Health Care, Inc. --- 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: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
RE: Any HIPAA Humor tools out there?
Also, for what it's worthit's a bit dated but you might be able to punch it up... I saw a newspaper cartoon of a doctor talking to a patient...the patient had a horrified look on her facethe caption was the doctor saying...did I have your medical records sent over? Heck no, I just downloaded them from Napster. Catherine Lohmeier Sr. Business Consultant PCI: e-commerce for healthcare ph. 402-304-1918 www.hipaasurvival.com --- 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: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
RE: Any HIPAA Humor tools out there?
How about: Helping Insure Profitability for American Attorneys Can you guess what law schools are promoting courses in successful litigation under HIPAA regulations? We have at least one here in Florida I am aware of. David Artis -Original Message-From: fwdanby [mailto:[EMAIL PROTECTED]]Sent: Wednesday, January 29, 2003 1:10 PMTo: WEDI SNIP Privacy Workgroup ListCc: WEDI SNIP Privacy Workgroup ListSubject: Re: Any HIPAA Humor tools out there? Get an acronym-matching contest going. Here's the first (and it's not original to me) Healthy Income Protection for Aggressive Attorneys F.W. (Bill) Danby, MD, Manchester, NH, USA - Original Message - From: Bentz-Miller, Judith To: WEDI SNIP Privacy Workgroup List Sent: Wednesday, January 29, 2003 9:17 AM Subject: Any HIPAA Humor tools out there? does anyone have any good HIPAA humor training tools that they would bewilling to share? I am doing a presentation later today and I am lookingfor something different. Email me directly if you wish. Thank you for helping!---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 as the address subscribed to the list, please use the Subscribe/Unsubscribe 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 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe 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 be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
RE: Business Associate Question
In the context of using such temp agencies to provide fill-in staff, they
are in either case members of the workforce.
Darrell Rishel, J.D.
Director of Information Services
Arapahoe House, Inc.
This message is not legal advice or a binding signature.
-Original Message-
From: Giesecke, Steve [mailto:[EMAIL PROTECTED]]
Sent: Wednesday, January 29, 2003 12:42 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Business Associate Question
Would appreciate responses to the following BA classification determination:
With respect to Nurse staffing and other medical staffing agencies,
including home health care, my assessment is that if nurses are providing
treatment services, they (generally) are not BA's and no BAA is needed (as
with a provider - provider or plan - provider relationship; treatment
exemption applies). If they are providing other professional or
administrative services such as UM/QM/CM ( come into contact with PHI) then
a BAA with the agencies providing them is needed.
Don't want to oversimplify in terms of my assumptions, however anywhere in
HIPAA you can simplify is good!
Thank you,
Steve Giesecke
Independent Consultant
Subcontractor to Sierra Systems
(360) 561-3803
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you wish to receive an official opinion, post your question to the WEDI SNIP Issues
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RE: Any HIPAA Humor tools out there?
Or High Income Potential for Aggressive Attorneys Bruce Bradigan How about: Helping Insure Profitability for American Attorneys Can you guess what law schools are promoting courses in successful litigation under HIPAA regulations? We have at least one here in Florida I am aware of. David Artis -Original Message- From: fwdanby [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 1:10 PM To: WEDI SNIP Privacy Workgroup List Cc: WEDI SNIP Privacy Workgroup List Subject: Re: Any HIPAA Humor tools out there? Get an acronym-matching contest going. Here's the first (and it's not original to me) Healthy Income Protection for Aggressive Attorneys F.W. (Bill) Danby, MD, Manchester, NH, USA - Original Message - From: Bentz-Miller, mailto:[EMAIL PROTECTED] Judith To: WEDI SNIP Privacy Workgroup mailto:[EMAIL PROTECTED] List Sent: Wednesday, January 29, 2003 9:17 AM Subject: Any HIPAA Humor tools out there? does anyone have any good HIPAA humor training tools that they would be willing to share? I am doing a presentation later today and I am looking for something different. Email me directly if you wish. Thank you for helping! --- 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe 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 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org - This message was sent via the BiznessOnline.com webmail system. http://www.biznessonline.com --- 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: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
RE: Any HIPAA Humor tools out there?
Who's doing this? Can you guess what law schools are promoting coursesin successful litigation under HIPAA regulations? Wehave at least one here in Florida I am aware of. Please let me know, I'd love to see the curriculum andfigure out the holes in it, perhaps work up articles to help judges reject HIPAA claims. Something like this would becounter-productive andwould require creative lawyering to develop strong private claims (or is the training is for prosecutors or OCR investigators?) By the way,this is one attorney who co-presented abouttwo dozen half-day statemedical association sponsored trainings for docs, including a thick compliance manual, for compensation that basically covered expenses, i.e.pro bono. And no, I don't get a lot of work from docs - a little from time to time, not much, doctors don't trust lawyers and don't want to spend money on them (and get mad at us when they messup legal matters trying to do it themselves and it costs them more to fix the problems they caused!) - not my client base, but a profession I respect and felt needed the help since nobody else was stepping up to the plate. Just a thoughtto keep lawyer slamming in perspective. John R. Christiansen Preston | Gates | Ellis LLP PLEASE NOTE OUR NEW ADDRESS AND PHONE NUMBERS EFFECTIVE TUESDAY, JANUARY 21: 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104 (Direct: 206.370.8118 (Cell: 206.683.9125 * [EMAIL PROTECTED] Notice: Internet e-mail is inherently insecure. Unencrypted e-mail may be accessible to unauthorized viewers, content may be modified or corrupted, and headers or signatures may incorrectly identify the sender. If you wish to confirm this message or the identity of the sender, please contact me using a communications channel other than a "reply" to this e-mail. Secure electronic messaging is available and recommended for confidential or sensitive communications. --- 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: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
RE: NPP revisions
My non-legal opinion is that this is overkill...and that patients will annoyed. I don't believe that was the intent of the privacy regulations. 1. Why do you expect your NPP to change frequently? Is it so specific that every new request for data (such as from a new accreditation agency) will cause it to be updated? 2. Could you date or letter your NPP so it is easier to recognize which edition/version was given? If your application can accomodate a yes/no to show they received it, why could it not accomodate a date or letter? 3. Think of the costs of this practice. Will you be keeping paper copies, which must be filed, or electronic copies, which take up disk space? My personal opinion only. Mimi Mimi Hart Ó¿Õ* Research Analyst, HIPAA Iowa Health System 319-369-7767 (phone) 319-369-8365 (fax) 319-490-0637 (pager) [EMAIL PROTECTED] Matthew Rosenblum [EMAIL PROTECTED] 01/29/03 18:56 PM Traci, You will still need to maintain (and track) those signed-acknowledgements. In the Committee's plan, it seems that there will be many more acknowledgements to maintain. I hope that this helps. Your questions are always welcome. Matt Matthew Rosenblum Chief Operations Officer Privacy, Quality Management Regulatory Affairs http://www.CPIdirections.com http://www.cpidirections.com/ CPI Directions, Inc. 10 West 15th Street, Suite 1922 New York, NY 10011 (212) 675-6367 [EMAIL PROTECTED] CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by E-Mail at the address shown and delete the original message. Thank you. AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener información privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si usted ha recibido esta comunicación por error, por favor no lo distribuya. Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message- From: Noel, Linda A. [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 3:15 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: NPP revisions Expense. Linda Noel Corporate Privacy Officer Corporate Compliance Orlando Regional Healthcare 321-843-8693 -Original Message- From: Traci Winter [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 2:27 PM To: WEDI SNIP Privacy Workgroup List Subject: NPP revisions 164.520 [c][2][iv] Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision and promptly comply with the requirements of paragraph [c][2][iii] of this section, if applicable. I just want to run this by everyone, in our HIPAA committee meeting today we have decided to provide a NPP and get a signed acknowledgement of receipt with each admission to home care services, even if the patient was previously receiving services from our agency. The reasoning is, with the rapid turnover of our patients it would be extremely difficult to track which edition of our NPP a patient had received, and since our patients sometimes are re-admitted to our services years down the road it would allow us to make sure we had documentation that the NPP had been given. We may put a section on our acknowledgement form for the patient to check/sign if they are refusing a copy due to previous receipt. I think this should cover us pretty well**. any cons to the plan? Traci Winter Hospitals Home Health Care, Inc. --- 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org This e-mail message and any attached files are confidential and are intended solely for the use of the addressee(s) named above. If you are not the intended
RE: Business Associate Question
Steve, You are correct. UM/UR is a payment activity, and many QM activities are health care operations. When performed by the nurses (as you described below), the nurses would be acting in the capacity of BAs, and a CE would want to consider signing a BAC with the agency that provides the help. However, please note that in the Preamble to the (initial) Final Privacy rules, HHS says that, .independent contractors may or may not be workforce members. However, for compliance purposes we will assume that such personnel are members of the workforce if no business associate contract exists. I hope that this helps. Your questions are always welcome. Matt Matthew Rosenblum Chief Operations Officer Privacy, Quality Management Regulatory Affairs http://www.CPIdirections.com CPI Directions, Inc. 10 West 15th Street, Suite 1922 New York, NY 10011 (212) 675-6367 [EMAIL PROTECTED] CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by E-Mail at the address shown and delete the original message. Thank you. AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener información privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si usted ha recibido esta comunicación por error, por favor no lo distribuya. Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message- From: Giesecke, Steve [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 2:42 PM To: WEDI SNIP Privacy Workgroup List Subject: Business Associate Question Would appreciate responses to the following BA classification determination: With respect to Nurse staffing and other medical staffing agencies, including home health care, my assessment is that if nurses are providing treatment services, they (generally) are not BA's and no BAA is needed (as with a provider - provider or plan - provider relationship; treatment exemption applies). If they are providing other professional or administrative services such as UM/QM/CM ( come into contact with PHI) then a BAA with the agencies providing them is needed. Don't want to oversimplify in terms of my assumptions, however anywhere in HIPAA you can simplify is good! Thank you, Steve Giesecke Independent Consultant Subcontractor to Sierra Systems (360) 561-3803 --- 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: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
Authentication of IVR users
How are folks addressing the authentication of providers (or their staff) into an IVR system that provides eligibility information about members? This question can also be generalized to any means of communication - how do you authenticate a live caller who claims to be from a provider office, or a web user? The IVR system in question is typically used to check eligibility on the spot for a presenting patient. It can be a contracted or non-contracted provider calling the IVR, so maybe the provider is known in some way to the healthplan or maybe not. Requiring that the provider register in some fashion to be able to get eligibility information from an IVR seems to be reasonable so long as current capability is still available while performing the registration process. One of the things we're kicking around is allowing a non-registered provider to receive extremely basic information (eligible Y/N, since what date, copay =$x), and maybe not even confirm back the name of the member whose ID was entered, just confirm what number was entered. For a registered provider who identifies him/herself via a login PIN, we would confirm back the member's name, provide all the basic information plus whatever else is appropriate. Any thoughts? Maria Hatz HIPAA Project Management This electronic message transmission, including any attachments, contains information from PacifiCare Health Systems Inc. which may be confidential or privileged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify the sender immediately by a reply to sender only message and destroy all electronic and hard copies of the communication, including attachments. --- 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: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
Re: NPP revisions
Yes, it is not necessary. You only have to obtain written acknowledgment of an individual's receipt of your NPP one time (on the first service delivery after the compliance date). After that, if you subsequently revise your NPP you only need to post the revised notice in your facility, and make it available to people on request. There is no need to track which version of the NPP they received, nor is there a requirement to obtain another acknowledgment if you issue a later revision of your NPP. I believe this has been clarified on the CMS web site thorugh their FAQ's, and in the December guidance issued by OCR. I'm sure I could cite you the exact source if you have trouble convincing your other committee members. Noel Chang -- Open WebMail Project (http://openwebmail.org) -- Original Message --- From: Traci Winter [EMAIL PROTECTED] To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED] Sent: Wed, 29 Jan 2003 14:26:30 -0500 Subject: NPP revisions 164.520 [c][2][iv] Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision and promptly comply with the requirements of paragraph [c][2][iii] of this section, if applicable. I just want to run this by everyone, in our HIPAA committee meeting today we have decided to provide a NPP and get a signed acknowledgement of receipt with each admission to home care services, even if the patient was previously receiving services from our agency. The reasoning is, with the rapid turnover of our patients it would be extremely difficult to track which edition of our NPP a patient had received, and since our patients sometimes are re- admitted to our services years down the road it would allow us to make sure we had documentation that the NPP had been given. We may put a section on our acknowledgement form for the patient to check/sign if they are refusing a copy due to previous receipt. I think this should cover us pretty well... any cons to the plan? Traci Winter Hospitals Home Health Care, Inc. --- 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- End of Original Message --- --- 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: archive@mail-archive.com 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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
