Re: Another OHCA question
The way that I have interpreted the reg is the following: The ER docs and Radiologists are by definition an OHCA with the hospitalor should I say they are an integrated care setting and therefore meet the definition -and therefore can CHOOSE to do a joint notice if they want to.the notice will specify who is covered and where. I don't think anything official needs to be done to declare yourselves an OHCA - each provider(CE) must agree to abide by the joint notice - which leaves you various avenues in which to accomplish this. The guidance issued in December - Original Message - From: NANCY MARTIN To: WEDI SNIP Privacy Workgroup List Sent: Tuesday, March 04, 2003 1:39 PM Subject: Another OHCA question I am helping our groups of hospital-based radiologists and emergency physicians comply with HIPAA. My understanding has been that the hospital-based rad's and er doc's operate under the facility's notice of privacy practices, with or without an official OHCA document. In other words, forming an OHCA is not necessary. How are others approaching this? Nancy Martin Director of Compliance OPS --- 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: Are DME Vendors BA?
The test is disclosures to other "health care providers" involving the "treatment" of the individualIf I remember correctly, DME vendors meet the definition of health care provider under HIPAA. This definition refers you to another regulation that you must review. Once you review this definition, you may be able to shorten your list of BA's! - Original Message - From: "Vikas Budhiraja" <[EMAIL PROTECTED]> To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]> Sent: Friday, February 21, 2003 12:52 PM Subject: Are DME Vendors BA? > Hello, > Had a question about vendors of DME (Durable Medical Equipment). If a > Provider contacts a DME vendor and informs about a patient who needs a DME > for home care, > does the provider need to have a BA with the DME vendor before this can be > done? > Or would this be treated as part of treatment? > > Regards, > Vikas > > > --- 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: OCHA
We are doing an Administrative Policy that the Med Exec Committee will approve. The policy states that they agree to abide by our Joint Notice of Privacy Practices. HIPAA does NOT require you to "designate" yourselves as an OHCA, unlike Affiliated Entity status which does. I believe that the Privacy Reg defines a relationship that already exists and therefore you are only left with finding a "method" of documenting that the medical staff agree to abide by the joint notice. To try and get them all to sign an agreement sounds like a tracking nightmare to me. - Original Message - From: "Nancy Jones" <[EMAIL PROTECTED]> To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]> Sent: Wednesday, January 22, 2003 8:54 AM Subject: OCHA > I want to find the easiest method (that complies with the law) for > documenting an OCHA with our physicians. Does this mean I need > individual written agreements between our hospital and each physician > with privileges? If so, is anyone willing to share a sample, as I can't > find one anywhere. > > Or can this be done by simply revising the Medical Staff Bylaws and > including a declaration that an organized health care arrangement exists > between the docs and the hospital, and that we have jointly designed a > NPP? > > Some area hospitals are asking their docs to sign Confidentiality > Statements on top of everything else. This seems too much to me. > > Any guidance will be greatly appreciated. --- 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