RE: Disclosing Claims Info to Fully-Insured Group Moving to Self-Fund ed

2003-03-24 Thread David Ermer
There's a complete discussion of this issue in the WEDI SNIP Privacy Policies and Procedures Ver. 2.0 (fully updated for the 8/14 modifications to the Privacy Rule.) Look at the Group Health Plans chapter in the General section. For a copy head to snip.wedi.org and click on work products --

Re: NPP in Other Languages

2003-03-18 Thread David Ermer
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

RE: Amendment Questions

2003-03-03 Thread David Ermer
original. Gracias. -Original Message- From: Matthew Rosenblum [mailto:[EMAIL PROTECTED] Sent: Saturday, March 01, 2003 12:15 AM To: 'David Ermer'; '[EMAIL PROTECTED]' Subject: RE: Amendment Questions Dave, I must respectfully disagree with your application of the QA that you cited (below

RE: Amendment Questions

2003-03-02 Thread David Ermer
notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message- From: David Ermer [mailto:[EMAIL PROTECTED] Sent: Friday, February 28, 2003 10:26 PM To: [EMAIL PROTECTED]; [EMAIL PROTECTED] Subject: RE: Amendment Questions Matt -- Here

RE: Amendment Questions

2003-02-28 Thread David Ermer
Matt -- I respectfully question your response. The Privacy Rule, 45 CFR § 164.526(a), states that individuals have the right to request an amendment as long as the CE holds the PHI in a designated record set. Neither § 164.526 or § 164.524 (the access right) create an exception for PHI created or

RE: Amendment Questions

2003-02-28 Thread David Ermer
notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message- From: David Ermer [mailto:[EMAIL PROTECTED] Sent: Friday, February 28, 2003 10:20 AM To: WEDI SNIP Privacy Workgroup List Subject: RE: Amendment Questions Matt -- I

Re: DOL vs. HIPAA

2003-02-20 Thread David Ermer
Michele -- I am not aware of any HHS statement in the 12/28/2000 preamble to the effect that diagnosis information must be stripped from the EOB in order to achieve Privacy Rule compliance. I have quoted the relevant preamble statements below my signature. Although HHS has not issued any dictates

Re: Disclosures

2003-02-17 Thread David Ermer
Teri -- You are overstating the accounting for disclosures requirenment. Under the modified final rule, the only disclosures that are subject to the accounting for disclosure under § 164.528 are most post-4/14/03 (but not all) disclosures that are made without an authorization under § 164.512

Re: Costs

2002-10-21 Thread David Ermer
--- 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