Email and HIPAA

2003-03-24 Thread Christiansen, John (SEA)
For those looking into email issues specifically, please see HealthyEmail,
www.healthyemail.org . It's a nonprofit, I'm on the board, and the point of
the exercise is to get policy and procedural tools out to support the
clinical (principally physician practice) use of email. The other advisors
are heavy hitters in this area (Bill Braithwaite, Danny Sands who was
principal author of the AMIA email guidelines, Paul Tang, etc.), and we have
posted a non-proprietary primer addressing HIPAA and other risks (I am
generally more concerned about those other risks, by the way), patient
communications documents, etc.

Disclosure: It's a nonprofit principally supported by a secure messaging
vendor which is a client of mine.  Well, does anybody know of a health
system, governmental agency or academic body who's going to pay for any
major new initiative these days? And this way I know who they're listening
to for advice. You can judge the merits of their solution for yourself, if
you like, or ping me off list for info. The HealthyEmail documentation
itself is not tied to the vendor, and is designed to support any clinical
use of email.

Interested party or not, my take is that if there is reasonably
affordable/reasonably easy to use encryption available, the addressable
specification security rule analysis indicates it should be used if you
send ePHI over the Internet with any frequency. 

John R. Christiansen
Preston | Gates | Ellis LLP
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.
 

-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
Sent: Monday, March 24, 2003 4:43 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: New to this list, have two questions.


We have been wrestling with this question of e-mail security here too.
I am with a large integrated delivery system in New Mexico.
 
Our position, however, is that we will not stop the e-mail until we can
agree on a workable technical security approach.
We will continue as we have been, while we simultaneously working on a
technical security approach 
(I won't say solution, because there does not appear to be a great
solution at this time.)
 
We believe it is too risky from a patient care standpoint to completely stop
all e-mail, for a couple of reasons:
1) Most of our clinical units use e-mail to communicate with other providers
and with patients themselves regarding treatment and care management
2) There have not been any reported problems with security related to this
so far (I understand that this doesn't mean there is no risk).  Therefore in
comparing the benefits and risks to the patient, we felt it was better to
continue using e-mail for now.
3) We feel that the advantages of e-mail outweigh the security risks;
specifically we see those advantages as:  

*   speed, 
*   written documentation of the communication, and 
*   the fact that both parties don't have to be in communication at the
same time (like the phone would require) 

4) The best alternative to e-mail would be fax - but that really is not much
safer than e-mail from a technical standpoint, and in many cases travels
over the same lines.  We don't feel like we are buying much in terms of
additional security by forcing everyone to use fax.  Also, many patients do
not have home fax machines.
 
We are currently working on developing a secure server approach.
We feel that encryption is not realistic since the technology is not
standard enough, nor easily usable by clinicians or patients.
 
We see our biggest challenge with any technical approach, is not the
technology, but getting our clinicians and administrative staff to adopt it.
Most of our planning will be focused on piloting and adoption strategies for
this type of technology, from a very practical standpoint.
 
Is any body else seeing the adoption challenges of e-mail security
technology?
 
Julie Fulcher 
HIPAA Project Manager 
Presbyterian Healthcare Services 
Albuquerque, New Mexico 87125- 
(505) 923-6397 
[EMAIL PROTECTED] 

 

-Original Message-
From: Doug Webb [mailto:[EMAIL PROTECTED]
Sent: Monday, March 24, 2003 1:45 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: New to this list, have two questions.


Gregory,
Just to amplify on Judith's remarks,
You are exposed to the risk NOW, not when the final Security Rule fully
kicks in.
You are accepting a huge risk anytime you expose PHI to the Internet.
Remenber that any of the millions of computers on the 

RE: NPP in Other Languages

2003-03-18 Thread Christiansen, John (SEA)
Folks -

The plain language requirement for the NPP incorporates regulatory
requirements that include translation into other languages if they are a
material element of the population you serve. I did the research well over a
year ago so don't recall the citations, and don't have time to dig it up
just now, but I believe it was available via an OCR webpage. There are
criteria for determining what languages you need to include, and this would
apply to any CE, not just an employer plan.

John R. Christiansen
Preston | Gates | Ellis LLP
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.


-Original Message-
From: David Ermer [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 18, 2003 1:53 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: NPP in Other Languages


It strikes me as an attorney who represents ERISA governed health plans
that the NPP can be considered a material modification to the health
plan under the U.S. Labor Department's (DOL) rules. DOL, in contrast to
HHS, has very specific rules on distributing a summary plan description
or a summary of material modifications to a plan participant, i.e., hand
delivery, first class mail (second or third class only if return and
forwarding postage is guaranteed and address correction is requested),
or electronic delivery under certain circumstances and on when you need
to translate such plan documents into another language. If your covered
entity is governed by ERISA, I suggest that you apply these rules. If
you covered entity is not governed by ERISA, you still may find the
guidance helpful. I have quoted the foreign language and mailing
guidance below. Best regards, Dave Ermer

29 C.F.R. §2520.102-2 Style and Format of SPD:

(c) Foreign languages. In the case of either--
(1) A plan that covers fewer than 100 participants at the beginning

of a plan year, and in which 25 percent or more of all plan
participants 
are literate only in the same non-English language, or
(2) A plan which covers 100 or more participants at the beginning
of 
the plan year, and in which the lesser of (i) 500 or more participants,

or (ii) 10% or more of all plan participants are literate only in the 
same non-English language, so that a summary plan description in
English 
would fail to inform these participants adequately of their rights and

obligations under the plan, the plan administrator for such plan shall

provide these participants with an English-language summary plan 
description which prominently displays a notice, in the non-English 
language common to these participants, offering them assistance. The 
assistance provided need not involve written materials, but shall be 
given in the non-English language common to these participants and
shall 
be calculated to provide them with a reasonable opportunity to become 
informed as to their rights and obligations under the plan. The notice

offering assistance contained in the summary plan description shall 
clearly set forth in the non-English language common to such 
participants offering them assistance. The assistance provided need not

involve written materials, but shall be given in the non-English 
language common to these participants and shall be calculated to
provide 
them with a reasonable opportunity to become informed as to their
rights 
and obligations under the plan. The notice offering assistance
contained 
in the summary plan description shall clearly set forth in the non-
English language common to such participants the procedures they must 
follow in order to obtain such assistance.

Example. Employer A maintains a pension plan which covers 1000 
participants. At the beginning of a plan year five hundred of Employer

A's covered employees are literate only in Spanish, 101 are literate 
only in Vietnamese, and the remaining 399 are literate in English. Each

of the 1000 employees receives a summary plan description in English, 
containing an assistance notice in both Spanish and Vietnamese stating

the following:
``This booklet contains a summary in English of your plan rights
and 
benefits under Employer A Pension Plan. If you have difficulty 
understanding any part of this booklet, contact Mr. John Doe, the plan

administrator, at his office in Room 123, 456 Main St., Anywhere City,

State 20001. Office hours are from 8:30 A.M. to 5:00 P.M. Monday
through 
Friday. You may also call the plan administrator's office at (202)
555-
2345 for assistance.''

29 C.F.R 

RE: Security Requirements

2003-03-13 Thread Christiansen, John (SEA)



Not 
that knowing that is much help in figuring out what you need to do . . 
.

John R. Christiansen Preston | Gates | 
Ellis LLP 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.

  -Original Message-From: KERBER, JEFF 
  [mailto:[EMAIL PROTECTED]Sent: Thursday, March 13, 2003 10:32 
  AMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: 
  Security Requirements
  Yes, 
  that's exactly how to read that.
  
-Original Message-From: Daryn Thompson 
[mailto:[EMAIL PROTECTED]Sent: Thursday, March 13, 2003 
12:18 PMTo: WEDI SNIP Privacy Workgroup ListSubject: 
Security Requirements

In the final security document, 
you have standards. Some 
standards have implementation specifications and others do not. On the standards that do have them, 
they are REQUIRED or ADDRESSABLE. 
On the ones that do not have specifications, are they 
Required?

Daryn 
Thompson 

Network/I.S. 
Coordinator
(801) 
468-2123
---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 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 named as recipients in the message. If you 
  are not an intended recipient of the message, please notify the sender 
  immediately and 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."
---
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 

RE: Any HIPAA Humor tools out there?

2003-01-29 Thread Christiansen, John (SEA)



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: Here is a good Privacy Issue that will cause problems

2003-01-17 Thread Christiansen, John (SEA)
tity 
  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: 
  Christiansen, John (SEA) [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 
  16, 2003 7:09 
  PMTo: WEDI SNIP Privacy Workgroup 
  ListSubject: RE: Here is a 
  good Privacy Issue that will cause problems
  
  
  Hate to 
  say it, but I disagree: Under HIPAA a pharmacist's job is to establish and 
  comply with certain policies for privacy, security and electronic claims 
  processing. It is a pharmacist's *professional* obligation to avoid (or 
  mitigate) harm to individuals, and HIPAA is not intended to *interfere* with 
  this. But HIPAA says nothing about mitigation of harm or professional 
  standards.
  
-Original 
Message-From: Matthew 
Rosenblum [mailto:[EMAIL PROTECTED]]Sent: Thursday, January 
16, 2003 3:57 
PMTo: WEDI SNIP Privacy Workgroup 
ListSubject: RE: Here is a 
good Privacy Issue that will cause problems
Tim,

I must 
respectfully disagree with your fundamental analysis of this scenario. 
Pharmacists (chemists) have, for more than 2000 years, been part of a triad 
(including physicians and nurses) engaged in an on-going clinical (NOT 
business) practice of ensuring that the correct medications and drugs are 
received by the correct patients. Whenever we remove one of those 
clinical disciplines from the decision-making process, medication errors and 
mistakes are likely to increase.

It is 
NOT the intention of HIPAA to deter a good clinical practice. 
Unfortunately, when unscrupulous people get hold of blank-prescriptions, 
innocent people may get hurt. Under HIPAA, our responsibility then 
becomes mitigation of the harm.

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: 
[EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 16, 2003 6:00 
PMTo: WEDI SNIP Privacy 
Workgroup ListSubject: RE: 
Here is a good Privacy Issue that will cause problems

In my 
personal opinion, this practice - violating patient privacy, in the name of 
detecting abuse by private businesses - which is (it appears to me) 
unsupported by statute (unless mandated by DEA regulation) - is contrary to 
both many state laws and HIPAA. I agree the practice serves a valuable 
community need, as well as the needs of the abusing patient 
(intervention). However, as it (as I see it) is NOT a law enforcement 
reporting issue, but rather a "home grown" solution, that business simply do 
out of common sense, the practice will either have to be suspended, with 
suspects reported to law enforcement - cutting out the Sherlock Holms 
detectionengaged in by pharmacistsin the process - or get a 
state statute passed to support and require the activity. After all, 
it appears to me that what is really occurring here is abuse of privacy, and 
potentially serious defamation, and that a case mi

RE: Here is a good Privacy Issue that will cause problems

2003-01-16 Thread Christiansen, John (SEA)



Hate 
to say it, but I disagree: Under HIPAA a pharmacist's job is to establish and 
comply with certain policies for privacy, security and electronic claims 
processing. It is a pharmacist's *professional* obligation to avoid (or 
mitigate) harm to individuals, and HIPAA is not intended to *interfere* with 
this. But HIPAA says nothing about mitigation of harm or professional 
standards.

  -Original Message-From: Matthew Rosenblum 
  [mailto:[EMAIL PROTECTED]]Sent: Thursday, January 16, 2003 3:57 
  PMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Here 
  is a good Privacy Issue that will cause problems
  
  Tim,
  
  I must respectfully 
  disagree with your fundamental analysis of this scenario. Pharmacists 
  (chemists) have, for more than 2000 years, been part of a triad (including 
  physicians and nurses) engaged in an on-going clinical (NOT business) practice 
  of ensuring that the correct medications and drugs are received by the correct 
  patients. Whenever we remove one of those clinical disciplines from the 
  decision-making process, medication errors and mistakes are likely to 
  increase.
  
  It is NOT the 
  intention of HIPAA to deter a good clinical practice. Unfortunately, 
  when unscrupulous people get hold of blank-prescriptions, innocent people may 
  get hurt. Under HIPAA, our responsibility then becomes mitigation of the 
  harm.
  
  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: 
  [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 
  16, 2003 6:00 
  PMTo: WEDI SNIP Privacy Workgroup 
  ListSubject: RE: Here is a 
  good Privacy Issue that will cause problems
  
  In my 
  personal opinion, this practice - violating patient privacy, in the name of 
  detecting abuse by private businesses - which is (it appears to me) 
  unsupported by statute (unless mandated by DEA regulation) - is contrary to 
  both many state laws and HIPAA. I agree the practice serves a valuable 
  community need, as well as the needs of the abusing patient 
  (intervention). However, as it (as I see it) is NOT a law enforcement 
  reporting issue, but rather a "home grown" solution, that business simply do 
  out of common sense, the practice will either have to be suspended, with 
  suspects reported to law enforcement - cutting out the Sherlock Holms 
  detectionengaged in by pharmacistsin the process - or get a state 
  statute passed to support and require the activity. After all, it 
  appears to me that what is really occurring here is abuse of privacy, and 
  potentially serious defamation, and that a case might be made for damages if a 
  person is placed on these distribution lists wrongly. However, as I am 
  not an attorney I can not pass on a formal opinion. Just keep in mind 
  that a person DOES NOT LOOSE ANY RIGHTS just because a pharmacist suspects 
  abuse!!! It is up to statutory law enforcement of investigate, and a 
  court to determine if a crime has been committed, NOT A CE, regardless of 
  their practices. I am frankly amazed that we have not heard more 
  litigation on this issue.
  
  Regards,
  
  Tim McGuinness, Ph.D.Consulting Specialist in 
  Regulatory Privacy, Security, and Application 
  Compliance---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 

RE: general question- help to get started!

2002-10-25 Thread Christiansen, John (SEA)
I can send you a copy of a presentation I did on employer compliance
obligations as plan sponsors, etc., if you like but we should do so
off-list. Let me know.

From: John R. Christiansen
Preston | Gates | Ellis LLP
701 Fifth Avenue, Seattle, Washington 98104
*Direct: 206.613.7118 - *Cell: 206.799.9388
* [EMAIL PROTECTED]
Reader Beware: Internet e-mail is inherently insecure. Unencrypted e-mail
may be accessible to unauthorized viewers, e-mail content may have been
modified or corrupted, and e-mail headers or signatures may incorrectly
identify the sender. If you wish to confirm the contents of this message or
identity of the sender, or wish to arrange for more secure communication
please contact me using a communications channel other than a reply to
this e-mail. Thank you.

 

-Original Message-
From: Susan Butters [mailto:sbutters;psd.k12.co.us]
Sent: Friday, October 25, 2002 1:45 PM
To: WEDI SNIP Privacy Workgroup List
Subject: general question- help to get started!


I hope that I have got the right group of people to ask- 
but here it goes! I apologize in advance if I don't. Any 
help would be appreicated. 

I am new to the HIPAA compliance project and am working 
with a school district that is self funded for health 
benefits and also has an internal EAP. Unique I think in 
the way that we are a plan sponsor and also a provider. 

Any insight or suggestions on the best resources to 
follow to get started and to follow?  


--
Susan Butters
HIPAA Compliance Specialist
Poudre School District, Ft. Collins, CO
[EMAIL PROTECTED]
970-490-3545



---
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@jab.org
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