RE: identification of people at front desk

2003-03-24 Thread Dan Kelsey
Ed - You might want to take a look at the December 4, 2002 clarification document.  In 
a nutshell, you can rely on professional judgment.  OCR stated that others can pick up 
prescriptions for the patient.  Chances are that the only way the individual knows to 
pick up the information, etc. is if the patient informed the individual.  For the 
majority of items, this should not be an issue - but if the person is picking a Rx for 
pain meds, etc, you might want to verify with the patient.

Hope this helps,

Dan Kelsey
Practice Advisor
Indiana State Medical Association
800-257-4762
(317) 261-2060
(317) 261-2076 - fax


-Original Message-
From: Ed Hecht [mailto:[EMAIL PROTECTED]
Sent: Monday, March 24, 2003 11:12 AM
To: WEDI SNIP Privacy Workgroup List
Subject: identification of people at front desk


We're a busy primary care office and often have people stop in to pick
up various things - referrals, prescriptions, letters, medical records,
etc.  Often it is not the patient him/herself.   What are we required to
do to:

a.  insure that the person is who s/he is supposed to be
b.  if it is not the patient, that s/he has the right to pick up the
material.  

 

We have already started to seal everything in an envelope, which we
didn't used to do.   Any guidance would be appreciated.  Thank you.

 

Ed Hecht, CEO, Piedmont Primary Care


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Address for Filing Complaints

2003-03-21 Thread Dan Kelsey
FYI - this was published in the yesterday's Federal Register and provides addresses 
for filing complaints under the privacy regulations:

http://www.hhs.gov/ocr/hipaahealth.pdf

Dan Kelsey
Practice Advisor
Indiana State Medical Association
800-257-4762
(317) 261-2060
(317) 261-2076 - fax


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RE: postcard reminders

2003-03-17 Thread Dan Kelsey



Kelli - Look at 
page 16 of the OCR clarification document dated December 3, 2002. This should 
answer your question - this follows under reasonableness.


Dan Kelsey Practice Advisor Indiana State 
Medical Association 800-257-4762 
(317) 261-2060 (317) 261-2076 - fax 

  -Original 
  Message-From: Kelli Caiafa 
  [mailto:[EMAIL PROTECTED]Sent: Monday, March 17, 2003 1:25 
  PMTo: WEDI SNIP Privacy Workgroup ListSubject: postcard 
  remindersI know this has probably been asked but please 
  reply again. Is there any concern with sending postcards (as compared to 
  a sealed envelope reminder) in the mail to remind patients to call and 
  schedule an appointment? The only information on the card would be the 
  patient's name and the physician's name. Thanks.
  Kelli Caiafa, MHS, NHA
  Regional Director
  Middlesex County Medical Society www.mcmsnj.org
  
  
  
  Do you Yahoo!?Yahoo! 
  Web Hosting - establish your business online --- The WEDI SNIP listserv to 
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EMS and Privacy Notice

2003-01-27 Thread Dan Kelsey
Last week, there was a fair amount of discussion re: EMS/Ambulance and the
provision of the privacy notice.  

Here is a thought from a non-EMS person:

In the majority of cases, patients are being transported to a hospital.
Couldn't you say that the ambulance/EMS service is participating in an
Organized Health Care Arrangement and that the ambulance/EMS could utilize a
joint notice in conjunction with the hospital?  In other words, operate
under the hospital's notice.  

What about using this same line of reasoning when transporting nursing home
patients?

One final thought - the rule requires that the notice be posted in a
publicly viewable area, etc.  I really don't think HHS expects an ambulance
to have the notice taped to the inside of the ambulance.  Thoughts??

Thanks

Dan Kelsey
Practice Advisor
Indiana State Medical Association

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RE: NPP and recurrent patients

2003-01-27 Thread Dan Kelsey
Actually, the December 2002 FAQ's addressed changes in the privacy notice
and state the following: 

Question:  Does the HIPAA privacy rule require a health care provider to
obtain a new acknowledgment of receipt of the notice from patients if the
facility changes its privacy policy?

Answer:  No.  A covered health care provider with a direct treatment
relationship with individuals is required to make a good faith effort to
obtain an individual's acknowledgment of receipt of teh notice only at the
time the provider firts gives the notice to the individual -- that is, at
first service delivery.  See 45 CFR 164.502(c)(2).

Hope this helps 

Dan Kelsey
Practice Advisor
Indiana State Medical Association

-Original Message-
From: Kelli Knuckles [mailto:[EMAIL PROTECTED]]
Sent: Monday, January 27, 2003 12:16 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: NPP and recurrent patients


Traci-

You only have to provide your patients with the NPP once.  You need to
somehow track that you have provided the patient with a copy.  One thing
to keep in mind, however, is that if you change or update your NPP new
copies need to be provided to your patients.  At least that's my
understanding.

Kelli Knuckles
Apps Analyst
MCDHS


 Traci Winter [EMAIL PROTECTED] 01/27/03 09:37AM 
OK time to open another can of worms.

It is not unusual for us to discharge a patient and have them return to
our services multiple times. Do have to give them a copy of the NPP each
time we admit them to services? Their medical records are only
maintained on site for the past year and current year, after that they
are sent to an off site storage facility. Should we just add a statement
to the acknowledgement stating a copy of the NPP wasn't provided or was
declined due to receipt at a previous time of admission. I know we had
this option with our patients rights booklet we gave out at time of
admission to hospital patients.

Traci Winter
Hospitals Home Health Care, Inc.


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