I tend to agree, Rachel, that on its face the relationship described by
Wendy meets the definition of a BA relationship. However, I must point out
that (my recollection of) the Rule as well as language from both the
Preamble and subsequent guidances refer to business associate activities as
being
Title: Federal Register Contents, Thursday, April 17, 2003
Go
to:
http://aspe.os.dhhs.gov/admnsimp/
and
check out the way DHHS spelled HIPAA when they posted the enforcement rule to
their own website.
-Original Message-From: Price, Carolyn
[mailto:[EMAIL PROTECTED]Sent:
remitente del E-Mail a la dirección mostrada y elimine el
mensaje original. Gracias.
-Original
Message-
From: Huber, Cheri
[mailto:[EMAIL PROTECTED]
Sent: Wednesday, April 02, 2003
5:17 PM
To: WEDI SNIP Privacy Workgroup
List
Subject: RE: Psychotherapy Notes
Bob,
My understanding
Unless there's some new animal out there I've not yet heard of it might
yield more results to request a sample OHCA agreement.
Just a thought.
-Original Message-
From: rachelmcass [mailto:[EMAIL PROTECTED]
Sent: Friday, April 04, 2003 9:59 AM
To: WEDI SNIP Privacy Workgroup
Except for
the EMTALA ramifications it sounds like the ideal solution.
-Original
Message-
From: Boyer, John (EOM)
[mailto:[EMAIL PROTECTED]
Sent: Friday, April 04, 2003 11:05
AM
To: WEDI SNIP Privacy Workgroup
List
Subject: RE: 10 Days to go, don't
bother opening if you don't
Based on
an informal poll it appears most psych professionals do not create or maintain
the sorts of notes that are defined by HIPAA as psychotherapy notes.
The HIPAA
exception evidently arose out of requests for special protection by those few
professionals who do create such notes.
Not
Rachel,
Since Leah and Dean already responded to the first part of your question
I'll just address the last part. Yes, 'wrongful' disclosures must be
included in an accounting.
Cheri
-Original Message-
From: rachelmcass [mailto:[EMAIL PROTECTED]
Sent: Wednesday, April 02, 2003
If you are going to include the contact information in your NPP you must use
the address and telephone number for your regional OCR office. and since I
don't know where you are located I can't say specifically but the details
are on pages 13711-12 of the Federal Register. Note, however, that you
Contrary laws that are either more stringent with regard to protection of
privacy OR grant more rights to the individual will preempt the HIPAA
Privacy Rule which merely sets a minimum federal standard - or floor - with
regard to medical information privacy. See 45 CFR 160 Part B - Preemption
of
I agree,
Deborah. I believe this was merely
an informational publishing on the part of DHHS. Covered entities are not, in the absence of instruction by
DHHS to do so, required to provide our patients with this information. However, in my organization we do plan
to provide the address if
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