Displaying Data in web browser . Indefinitely .
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. Do you Yahoo!? Yahoo! Web Hosting - establish your business online --- 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
RE: NPP type size?
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 --- 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: [EMAIL PR
RE: NPP type size?
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 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 discu
optical lab as health care provider
I’m 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 doctor’s 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 information from the law offices of Crary, Huff, Inkster, Sheehan, Ringgenberg, Hartnett, Storm & Jensen, P.C., which may be privileged, confidential, or otherwise protected from disclosure. The information is intended to be for the addressee only. If you are not the addressee, any disclosure, copy, distribution or use of the contents of the message or any attachments hereto is strictly prohibited. If you have received this electronic message in error, please notify us immediately and permanently delete the original message and attachments and any copies and destroy all hard copies of this message and any 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: [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
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 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
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 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
FW: DRS conf call
As follow up to the SNIP Policy and Procedure conference call on the Designated Record Set, I am forwarding the attached documents from Karen Williamson of the El Paso County Department of Health and Environment in Colorado. Karen very generously offered to share her tools for tracking the flow of PHI in an organization and for documenting the designate record set. See the following message from Karen for information on how she has used these tools. Joan Joan Boyle Privacy Officer and HIPAA Compliance Manager The TriZetto Group, Inc. Voice: 970-627-1675 Fax: 970-627-1677 [EMAIL PROTECTED] -Original Message- From: Karen Williamson [mailto:[EMAIL PROTECTED] Sent: Wednesday, March 12, 2003 5:19 PM To: Boyle, Joan Subject: DRS conf call Thank you for once again organizing a valuable conference call. Attached are the two documents that I referred to in my description of how I have approached the DRS determination. Don't know if this is something others would be interested in, but I'm willing to share! One document is the PHI flow (the pdf version didn't come out real clean, but you get the idea). Each of my Program Managers (at the Health Dept we have several programs such as STD, TB, Family Planning) needed to complete this worksheet -- it was there first assignment. I then took the PHI records they listed in the center column and listed them on the attached speadsheet. The second exercise (after a training that focused among other things on the definintion of DRS) was to determine if each of these PHI records would be included as part of our DRS. In doing this, they have realized that there are additional records that needed to be added to their list (not exactly what I wanted to hear!) -- maybe because they were seeing everyone else's list and this reminded them of other things. It is my intention that I, the Privacy Officer, will maintain the "Official List", available for inspection if any patient wants to know what is or is not included in our DRS. I will probably also include a statement in the NOPP or the form to request PHI that states that this list is available for their information, but it is subject to change. <> <> Karen Williamson Lead System Project Manager El Paso County Dept. of Health and Environment, CO 719 575-8468 phi flow worksheet.pdf Description: Binary data PHI - DRS _ blank.xls Description: MS-Excel spreadsheet --- 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
RE: NPP type size?
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 --- 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 re
Re: Self insured health plans & NPP
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.co
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 --- 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: [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 l
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 --- 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: [EMAI
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 --- 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: [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
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 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
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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
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 as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
Re: Filing deadline for complaints
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] "This electronic message may contain information that is confidential and/or legally privileged. It is intended only for the use of the individual(s) and entity(s) named as recipients in the message. If you are not an intended recipient of the message, please notify the sender immediately, delete the material from any computer, do not deliver, distribute, or copy this message, and do not disclose its contents or take action in reliance on the information it contains. Thank you." - 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 individualparticipants, and do not necessarily represent the views of the 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 discussion of specific vendor products andservices. They also are not intended to be used as a forum for personaldisagreements 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 athttp://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 asthe address subscribed to the list, please use the Subscribe/Unsubscribeform 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: [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 c
RE: A tricky BA Questions
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] *** The information in this email is confidential and may be legally privileged. It is intended solely for the addressee. Access to this email by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful. * -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 --- 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
Fwd: Security Requirements
--- Begin Message --- All standards are required. The ones without any implementation specifications are required. Stanley Nachimson Office of HIPAA Standards, CMS 410-786-6153 >>> <[EMAIL PROTECTED]> 03/13/03 02:50PM >>> F Y I --- End 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: [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
BA with Nursing Homes
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 --- 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
RE: Filing deadline for complaints
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 --- 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