Re: NPP in the waiting room
Craig, At the HHS/OCR conference in Atlanta, the head of OCR stated that it was not enough to hang the NPP on the wall. He stated that there is a wealth of information, including contact numbers, in a NPP and that patients should have the opportunity to "take it home and read it." Jean Acevedo, LHRM, CPC, CHC Acevedo Consulting Incorporated > > > Unfortunately, I joined late, but I was informed that someone had commented > on HIPAA wallpaper in the CMS conference call earlier this week. It > seemed(from what I heard second hand) that it would be appropriate to use > notebooks or some sort of "contained" version of the NPP. Those who heard > specifically please comment > > Craig Moen > THERAPY 2000 > > Confidential Information > This email message is intended only for the person or entity to which it is > addressed. Unless otherwise indicated or obvious by the nature of this > transmittal, the information contained in this email message is privileged > and confidential, intended for the use of the intended recipient (or the > employee or agent responsible to deliver to the intended recipient), you are > hereby notified that any dissemination, distribution or copying of this > communication is strictly prohibited. If you are not the intended recipient, > please contact the sender by reply email and destroy all copies of the > original message > THERAPY 2000 > 1881 Sylvan Avenue Suite 210 > Dallas, Tx 75208 > > > -Original Message- > From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] > Sent: Friday, March 28, 2003 9:57 AM > To: WEDI SNIP Privacy Workgroup List > Subject: NPP in the waiting room > > > Is the requirement for the posting of the NPP satisfied in a provider's > office by having multiple copies in notebooks throughout the waiting room, > or does it have to be posted on the wall? > > Thanks very much. > > Vicki Saunders > Compliance Manager/Privacy Officer > [EMAIL PROTECTED] > > Confidentiality Notice: The information contained in this e-mail > transmission is confidential information and intended for the sole use of > the individual(s) or entity named in the message header. If you are not the > intended recipient, you are hereby notified that any dissemination, copying > or taking any action in reliance on the contents of this information is > strictly prohibited. If you receive this message in error, please notify the > sender of the error and delete this message, any attachments and all copies. > Thank you. > > --- > The WEDI SNIP listserv to which you are subscribed is not moderated. The > discussions on this listserv therefore represent the views of the individual > participants, and do not necessarily represent the views of the WEDI Board > of Directors nor WEDI SNIP. If you wish to receive an official opinion, post > your question to the WEDI SNIP Issues Database at > http://snip.wedi.org/tracking/. These listservs should not be used for > commercial marketing purposes or discussion of specific vendor products and > services. They also are not intended to be used as a forum for personal > disagreements or unprofessional communication at any time. > > You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] > To unsubscribe from this list, go to the Subscribe/Unsubscribe form at > http://subscribe.wedi.org or send a blank email to > [EMAIL PROTECTED] > If you need to unsubscribe but your current email address is not the same as > the address subscribed to the list, please use the Subscribe/Unsubscribe > form at http://subscribe.wedi.org > > > --- > The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions > on this listserv therefore represent the views of the individual participants, and > do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. > If you wish to receive an official opinion, post your question to the WEDI SNIP > Issues Database at http://snip.wedi.org/tracking/. These listservs should not be > used for commercial marketing purposes or discussion of specific vendor products and > services. They also are not intended to be used as a forum for personal > disagreements or unprofessional communication at any time. > > You are currently subscribed to wedi-privacy as: [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 htt
Re: named Privacy officer on NPP, posting
I agree with Deborah's response to both questions. At the HHS/OCR conference in Atlanta a few weeks ago, Richard Campanelli (Director of OCR) made it very clear that: If you don't get a Notice you haven't been provided with your rights. Also, that "Notice on the wall is not enough." He stated that the Privacy Rule's intention is that a direct treatment provider would provide each patient with a copy of the NPP - it has contact information on it and the individual should be able to take it home and read it. Mr. Campanelli was quite clear as to a CE's obligations relative to the NPP and that OCR would not look kindly on a CE who tried to cut corners. Jean Acevedo, LHRM, CPC, CHC. In a message dated 3/10/2003 12:51:32 PM Eastern Standard Time, [EMAIL PROTECTED] writes: > 1) yes, you can just list the title of the Privacy Officer. That is what we are > doing. Otherwise you have to redistribute every time your Privacy Officer changes. > 2) I don't think this meets the requirements. But I'd see what everyone else says. > 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: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] > Sent: Monday, March 10, 2003 12:39 PM > To: WEDI SNIP Privacy Workgroup List > Subject: named Privacy officer on NPP, posting > > > I have two quick questions for the group: > 1. When your Notice of Privacy Practices (NPP) says to contact the Privacy Officer > for such and such, does the Privacy Officer need to be a NAMED individual or can > you just list the title of the contact person (e.g., the Privacy Officer)? > 2.Since the law calls for a "posting" of the NPP, can we display a stapled copy > of our 6 page NPP in a locked bulletin board (which would then just show the first > page of the NPP) and then have a sign next to this "displayed" NPP that tells the > inquisitive patient where in our office they can get a complete copy of the NPP if > they wish? I realize that this proposal probably goes against the intent of this > provision of the law but would it be technically be sufficient to meet the > requirements of this provision? > Reasons behind such a proposal are 1. Space is a problem, 2. Hanging up a 6-8 page > NPP looks trashy. 3. All patient's will be personally handed the NPP so what's the > point of posting it anyway? 4. And we would be "posting" it, it's just that you > could not read all the pages of the posted version! > Thanks for all advice provided. > Rich Fairley > --- > 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 a
Re: Secondary Claims and Privacy
Mike, Disclosing the information about a patient that appears on an EOB when that disclosure is for the payment of another patient's bill is not allowed by the Privacy Rule. Allowing this would be contrary to not only the minimum necessary component of HIPAA but also to the incidental disclosures allowed - not to mention the spirit and intention of the law. While "paper" is still in place for submitting secondary insurances, yes, the provider should obliterate any identifiable information about any individual other than the patient in question. If the information was inadvertantly disclosed, I would think that fact would need to be on a list of disclosures for the affected individual, and, a plan to mitigate any potential damages and prevent further similar disclosures should be put into place. Jean Acevedo, LHRM, CPC, CHC > Is there any requirement for CEs to mark through the PHI on a paper remittance > document that does not pertain to the patient when submitting claim + remittance for > secondary payment for this patient? > or > If a CE decides not to mark through the information not pertaining to a patient then > in essence is the other patient information being used for something other then TPO > and needs to be tracked? Since no payment is being requested, and the patients are > probably not an insured for the payer. Or is this incidental exposure and falls > between the gaps. > I understand that many CEs already do mark through the other patient information, > but with HIPAA would this now be considered a requirement? > Hopefully, the above issue will no longer be a requirement when CEs do the > transactions and codes sets, but for the time being it still needs to be addressed. > Thanks, > Mike > --- > 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: acknowledgement of Notice of Privacy Practices (NPP)
Dr. Fairley, My firm is recommending that the NPP be developed and implemented as soon as possible just for the reason you mention: otherwise every patient who walks in the door on 4/15 will need to be provided with this document, any discussion/questions, etc. If you can implement this part of the Rule now, by 4/15 only new patients or those who haven't been in for a few months will need to be provided with your NPP. By beginning sooner than 4/15 there's a secondary benefit: by that date this may be SOP for front desk staff. Unfortunately, mailing the NPP does not suffice as a good faith effort to obtain the individual's acknowledgement unless you use a signature-on-receipt mail service - which could get expensive. If you do include an acknowledgement form (that is a good idea, by the way), then your staff will only have to collect them. Some practices are updating their patient registration form to include a statement of acknowledgement. As you know, this is a good time of the year to have all patients update their personal & insurance info. Jean Acevedo, LHRM, CPC, CHC ACEVEDO CONSULTING INCORPORATED 711 Golf Court Delray Beach, FL 33445 [EMAIL PROTECTED] > On April 15, 2003, we are anticipating that we simply do not have the staff >available to supply all patients that walk in our door with our NPP. It's hard to >find someone to do a job like this for only 3-4 months! We plan to hire college >students to accomplish this task when school let outs in May. > > Nevertheless, in order to be compliant with the April 15, 2003 deadline, is it >acceptable to mail out our NPP to scheduled patients ahead of time? > > Is the fact that we are mailing them out (and let's say we can keep track of who >got SENT one) sufficient in itself to meet the requirement of a "Good faith effort to >obtain acknowledgement of receipt of NPP"? That is, is simply mailing out the NPP >adequate? If such a plan is not adequate, what about if we included an >acknowledgement form in the mailing and asked the patient to return the form (and we >did NOT supply an envelop or stamp)? Would that be enough, even if no one > returns it? > > Thanks. > Rich Fairley MD > Dubuque, IA --- 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: Covered Entity or not
Susan, What a great mind you have (and I am not being facetious!)...never would have thought about Medicare electronically submitting to secondary insurance/Medigap! Guess that does snag a lot of small physician practices in the "covered entity" net. Anyone disagree? Jean Acevedo, LHRM, CPC, CHC > > Subj: Covered Entity or not > Date: 2/3/2003 10:19:41 AM Eastern Standard Time > From: [EMAIL PROTECTED] > To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]> > Reply-To: [EMAIL PROTECTED] > Sent from the Internet (Details) > > > Everyone, > We can argue all day long whether or not we are a covered entity, but I think it >makes good business decision to agree that you are if you send in claims and be done >with it. > > Look at this situation, I don't know if many doctors or support staff realize this: >Anytime a claim is sent to Medicare, paper or electronic, it is coverted into an >electronic transaction because Medicare forwards it to 2nd insurance companies. So >now you are a covered entity. The only way to get out of sending claims to Medicare >is not to treat anyone who may have Medicare. Who can afford to refuse to treat a >large portion of our society. Another kink- Medicare requires the doctor to file the >claim for the patient so don't think you can give the claim to the patient and he >files it for you. > > The loop holes for not being a covered entity is so small, you almost have to >practicing in the dark ages to not be a covered entity. > > I think you just have to resign yourself that if you practice and treat patient >whether cash practice or not, you ARE A COVERED ENTITY. At least that is what I am >advising our > clients, better safe than sorry. > > Thanks, > > Susan Bowes > Professional Procedures & Control > Practice Consulting Firm for the Small Practioner --- 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
