We are an acute care facility that will be implementing both an automated
process a manual process. After completing an extensive analysis and
several brainstorming sessions, we found that a lot of what we are required
to track is already documented in the patient's medical record. Those items
that are not will be submitted from the individual disclosing the
information to a centralized location (contact person) where the disclosure
will be logged into an ACCESS database.
When the patient requests an accounting, the contact person will pull the
patient's chart to review for the disclosures that are documented add to
the database. In turn, the database will print the report to give to the
patient. The database will also track any suspension requests received from
law enforcement, etc. and all requests that have been received from the
patient. I created this database for our organization and I know enough
about ACCESS to be dangerous (did not cost me thousands of dollars to
develop).
Employees who disclose patient information in error will have to complete an
incident report that will also be provided for tracking purposes. Any other
disclosures made via telephone to public health, coroner, etc. will be
documented and emailed to the contact person to add to the tracking
database.
Will this work? I hope so! I have thought about every way possible.
Obtaining the majority of disclosures from the patient's chart will get
better compliance than to add another step for our clinical staff to handle
while they are trying to take care of our patients. Patient Care comes
first!
Hope this information has helped some of you... email me directly if you
would like additional information.
Tina C. Lamb
HIPAA and Corporate Compliance Coordinator
St. Francis Hospital, Inc.
706/596-4411 x 5657
-Original Message-
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]
Sent: Monday, January 27, 2003 5:01 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: Accounting for disclosures
I work with a large healthcare system in New Mexico.
We also would like to know if other CE's are considering automated or manual
solutions for tracking disclosures and producing an accounting as required
by law.
Also, how are other CE's handling the issue of being able to report not only
their own disclosures, but also those made by Business Associates:
- do you plan to survey business associates each time a request for an
accounting comes in?
- do you plan to ask business associates to proactively report any
disclosures they make?
- how will you keep track of this?
Thanks!
Julie Fulcher
HIPAA Project Manager
Presbyterian Healthcare Services
Albuquerque, New Mexico 87125-
(505) 923-6397
[EMAIL PROTECTED]
-Original Message-
From: Halterman, Anita [mailto:[EMAIL PROTECTED]]
Sent: Friday, January 24, 2003 6:16 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Accounting for disclosures
The NMEH HIT sub workgroup intends to discuss accounting for disclosures
during the next HIT call. During our last call the topic came up for
discussion and I offered to post an email to a couple of listservs to
generate some discussion regarding this topic.
How have CE's been dealing with HIPAA's accounting requirements?
Do CE's have tools that they would be willing to share that might make it
easier for those who are still struggling with this subject to use to assist
them with sorting this requirement out?
Are CE's approaching the accounting requirements by using paper tracking
systems or through the use of electronic tracking systems?
If anyone has best practices that they would be willing to share about how
to address these issues, please share them.
Thank you,
Anita Halterman
HIPAA Integration and Transition (HIT) Co-Chair,
Health Policy Analyst
HIPAA Privacy and Security Coordinator
State of Alaska,
Department of Health and Social Services,
Division of Medical Assistance,
4501 Business Park Blvd., Suite 24
Anchorage, AK 99503-7167
(907)334-2431
---
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