DHHS conferences

2003-02-21 Thread Ken Steen
Title: DOL vs. HIPAA Our company HIPAA Officer attempted to register for The DHHS Privacy Rule Conferences in both New York and Chicago.  He was told that they are both full, and there is no room at available.    Will DHHS put on additional conferences?  Does anyone have any suggestions?  

RE: DOL vs. HIPAA

2003-02-21 Thread Kevin Fairlie
Title: DOL vs. HIPAA Linda -   We are not making this leap with our clients.  I reached this conclusion for two reasons: (1) the actual regulatory text does not give any indication that sending EOBs to only the employee is a permissible disclosure.  This guidance is found in the Privacy Ru

Re: Need for Business Associate Agreements

2003-02-21 Thread Doug Webb
Beth, The new Security reg does indicate that MOUs take the place of BAAs if both are government entities.  If one of the partys is, and one isn't, I don't know.   The opinions expressed here are my own and not necessarily the opinion of LCMH.   Douglas M. WebbComputer System EngineerLittle C

Re: Are DME Vendors BA?

2003-02-21 Thread Dawn Lenox
The test is disclosures to other "health care providers" involving the "treatment" of the individualIf I remember correctly, DME vendors meet the definition of health care provider under HIPAA. This definition refers you to another regulation that you must review. Once you review this definit

RE: Need for Business Associate Agreements

2003-02-21 Thread Deborah Campbell
It would depend if they "used or disclosed PHI" on your behalf. If they do, you need a BAA. Hope that helps. 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

Re: Need for Business Associate Agreements

2003-02-21 Thread Beth Miller
Hello, everyone -   This is a variation on the question about the need for BAA's.  My agency anticipates beginning a new federal contract soon.  As part of our original proposal, we obtained letters of intent from various partners who would be working with us on the contract if we were awar

RE: Are DME Vendors BA?

2003-02-21 Thread Dan Kelsey
Vikas - I would consider this part of treatment - as a result, a BAC would not be required. Dan Kelsey Practice Advisor Indiana State Medical Association 800-257-4762 (317) 261-2060 (317) 261-2076 - fax -Original Message- From: Vikas Budhiraja [mailto:[EMAIL PROTECTED]] Sent: Friday, Feb

Are DME Vendors BA?

2003-02-21 Thread Vikas Budhiraja
Hello, Had a question about vendors of DME (Durable Medical Equipment). If a Provider contacts a DME vendor and informs about a patient who needs a DME for home care, does the provider need to have a BA with the DME vendor before this can be done? Or would this be treated as part of treatment? Reg

disclosure lists

2003-02-21 Thread Sandy Bazemore
I am interested in how others are handling these disclosure lists.  We are a medium size hospital and physician clinic.  We have a great deal of our medical record computerized but not all of it.  But there, apparently, is much more to the disclosure list than just the medical record.  In p

Re: DOL vs. HIPAA

2003-02-21 Thread Hcs321
I tend to disagree the diagnosis is pivotal in deciding the truth of the EOB its also not disclosing PHI to anyone but the individual of concerned. You need to verify the request for payment is in line with the diagnosis. On CMS claim forms you have both the diagnosis and procedure information. Tha

Re: DOL vs. HIPAA

2003-02-21 Thread Doug Webb
Title: DOL vs. HIPAA Agree. Subject to the restriction that whatever is disclosed for any purpose be only the minimum necessary for that purpose (which applys to all disclosures indipendant of the medium).   Remember that the great difficulty in giving out info over the phone is making that w

Re: Sharing information with clinic owned HMO

2003-02-21 Thread Leah Hole-Curry
Judith, Under 164.504(g); covered entities that have multiple functions (e.g. a health plan and a health care provider) may use and disclose PHI of individuals who receive plan or provider services, but not both, only for the purposes related to the appropriate function being performed. So it s

DOL vs. HIPAA

2003-02-21 Thread Mendel, Linda R.
Title: DOL vs. HIPAA I was thinking that disclosures to an employee who calls GHP customer service re the claims of his or her spouse could extend to the type of information the employee would get on an EOB.  In other words, if the employee can get the info on a paper EOB, then we (the GHP) sh

Re: Nursing Homes and Ambulance Services

2003-02-21 Thread Doug Webb
Title: Message Kathy, The Nursing Home and Ambulance Service would both be Covered Entities if they do any of the covered functions electronically.  Business Associates are entities who do something on behalf of a Covered Entity.   The opinions expressed here are my own and not necessarily th

RE: Nursing Homes and Ambulance Services

2003-02-21 Thread Vikas Budhiraja
Title: Message Kathy, If you are referring patients to a Nursing Home as part of continuing treatment, they will not be your BA. Similarly Ambulance Services is also not a BA of a hospital.   Regards, Vikas -Original Message-From: Kathy Findley [mailto:[EMAIL PROTECTED]]Sent: Th

RE: DOL vs. HIPAA

2003-02-21 Thread David Frenkel
David, You have a good suggestion but unfortunately it is not all that uncommon for government legislation to conflict between federal agencies and departments. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 -Original Message

Re: DOL vs. HIPAA

2003-02-21 Thread David Blasi
I would just add that I hope that if CMS decides to expand on this in a Q&A or in whatever manner they choose that they consult with their counterparts at the DOL. I have made comments several times about the discrepancy between HIPAA and ERISA. It benefits everyone if as much information about h

Re: Posting of the notice

2003-02-21 Thread Patricia Conroe
We will just make mass copies of the notice and distribute them to all of our satellite locations. Then it hit me that our computer system isn't all connected so how can we document across all our locations that the patient already received the notice? Then I thought about how to pass informat