RE: Contract Between Anesthesia Group and Hospital

2003-03-26 Thread Clay, Roy III (NO)
Title: RE: Contract Between Anesthesia Group and Hospital As persons involved directly in the treatment of the patient, you do not need a business associate agreement. However, you may wish to include some language in the contract which declares that the relationship between your group and the

RE: BA v Trading Partner Agreements

2003-03-20 Thread Clay, Roy III (NO)
Title: RE: BA v Trading Partner Agreements Trading partner agreements are used between covered entities (usually a health care and an insurance plan or a clearinghouse) to govern the exchange of covered transactions. A business associate agreement is between a covered entity (like a health car

RE: Internet Pagers & Privacy

2003-03-06 Thread Clay, Roy III (NO)
Title: RE: Internet Pagers & Privacy If all that is sent is the patient's name and address, that should be fine. If there is additional information that would allow someone to infer some about the  patient's health status, something like: To: HIV On Call Nurse. Call patient John Doe at 555-55

RE: JCAHO BAA

2003-03-05 Thread Clay, Roy III (NO)
Title: RE: JCAHO BAA The JCAHO (as well as most of the other accreditation organizations) has taken the position that trying to field everyone's individual BAA would be too much of an administrative burden, therefore they will only accept their own. You are right but this is an exception to th

RE: Another thread on Security/Privacy question

2003-03-04 Thread Clay, Roy III (NO)
.  Just that it pertains to payment for services.Noel Chang--Open WebMail Project (http://openwebmail.org)-- Original Message ---From: "Clay, Roy III (NO)" <[EMAIL PROTECTED]>To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]>Sent: Mon, 3 Mar

RE: Another thread on Security/Privacy question

2003-03-04 Thread Clay, Roy III (NO)
Noel Chang [mailto:[EMAIL PROTECTED]] Sent: Monday, March 03, 2003 11:24 PM To: Clay,Roy III (NO); WEDI SNIP Privacy Workgroup List Subject: RE: Another thread on Security/Privacy question Roy, I disagree with your conclusion that your collection agency is not a BA, even if all you give

RE: Another thread on Security/Privacy question

2003-03-03 Thread Clay, Roy III (NO)
Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 -Original Message-From: Clay, Roy III (NO) [mailto:[EMAIL PROTECTED]] Sent: Monday, March 03, 2003 8:42 AMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Another thread on Security

RE: Another thread on Security/Privacy question

2003-03-03 Thread Clay, Roy III (NO)
Title: RE: Another thread on Security/Privacy question The name and the credit card number are not PHI under HIPAA. It does not become PHI until some health information is added. If the information contains CPT codes, for example,  then you would either need to include that information in the

RE: NPP and accounting for disclosures - was Medicare audits: op erations?

2003-02-15 Thread Clay, Roy III (NO)
Title: Message I think you may be confusing authorizations and notices. I think if the patient signed an authorization, say for a clinical trial, that said we will disclose your information to XYZ drug company and ABC University who are co-investigators on the project, those disclosures woul

RE: Any HIPAA Humor tools out there?

2003-01-30 Thread Clay, Roy III (NO)
Don't forget Alan Goldberg's HIPAA-ginity!   HIPAA-ginity - that exemption from HIPAA regulations that vanishes when a healthcare provider succumbs to the temptation of electronic billing. -Original Message-From: Ron Moore [mailto:[EMAIL PROTECTED]]Sent: Thursday, January 30, 2

RE: HIPAA privacy and telephone

2003-01-17 Thread Clay, Roy III (NO)
Title: RE: HIPAA privacy and telephone My feeling is that unless you have authorization from the patient, anything other than giving the results directly to the patient is not allowed. You wish you can have an opt-in question on the order of "Do we have your permission to leave medical informa

RE: Privacy: de-identification analysis (no safe harbor)

2003-01-16 Thread Clay, Roy III (NO)
Title: RE: Privacy: de-identification analysis (no safe harbor) You may want to check with your local university if they have a school of public health. The biostatistics department should have the means to provide you with that analysis. -Original Message- From: Tim Belcheck [mailto

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

2003-01-16 Thread Clay, Roy III (NO)
Title: RE: Here is a good Privacy Issue that will cause problems I would argue that releasing information that a patient has been restricted to one pharmacy is not a disclosure under HIPAA. A disclosure must contain a person's identifying information and information on their health status. I d

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

2003-01-15 Thread Clay, Roy III (NO)
Title: RE: Here is a good Privacy Issue that will cause problems I don't think you could justify a broadcast like "If this guy shows up in your office, don't let him have Percocet!" The pharmacist can communicate with the doctors that have written prescriptions for the patient but I don't thin

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

2003-01-15 Thread Clay, Roy III (NO)
Title: RE: Here is a good Privacy Issue that will cause problems It seems to me that the act of issuing and filling a prescription is a treatment process therefore the minimum necessary standard would not apply. I don't think that the privacy rule prohibits such communications. The pharmacist