This has been included in OCR's material for the National
Conferences and stated by OCR at several recent teleconferences.
regards, lhc
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information transmitted is confidential and may be proprietary to FOX
Systems, Inc. It is intended only
ssary doesn't apply to disclosures to or
requests by a health care provider for treatment.
And under 164.506(c)(1) - covered entities can use/disclose PHI for its
own treatment activities and (2) for treatment activities of (another)
health care provider.
Regards, lhc
Leah Hole-Curry, JD
FOX Sy
internal) the information,
without the need for a business associate agreement (because they are
members of the same workforce).
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information transmitted is confidential and may be proprietary to FOX
Systems, Inc. It is intended only for the person
e disposal, janitors, transcription and other secretarial
services, etc. The need for business associate agreement is dependent
on whether access to PHI is necessary to accomplish the service.
Regards, lhc
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information transmitted is confidential
technical solution is mandated (e.g.
re-programming screens and access), perhaps once appropriate access is
identified, some procedural requirements about which files to access and
conditions on use will suffice.
regards, lhc
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information tran
ly conditioning
disclosures to such business associate functions on individuals'
authorization. 67 Fed. Reg. pages 53206, 53207.
As noted, this isn't directly on point, but it does states that the the
Notice is not a substitute for other requirements: you need both.
Regards, lhc
Leah H
tion with a standard transaction
(e.g. claims, eligibility, encounter, claims status, referal
certification and authorization, etc.)
Regards, lhc
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information transmitted is confidential and may be proprietary to FOX
Systems, Inc. It is intended only for
42 U.S.C. Section 1320d-5 (General Penalty for Failure to comply with
Requirements and Standards)
The pre-codified version is on HHS' website at:
http://aspe.hhs.gov/admnsimp/pl104191.htm
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information transmitted is confidential and m
uld need a special form because the language will be
different from the general circumstances where you cannot condition
treatment or where it is combined with other types of
permission/information.
lhc
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information transmitted is confidential
is limited to what is necessary and assure that its
in the interests of the patient.
Regards, lhc
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information transmitted is confidential and may be proprietary to FOX
Systems, Inc. It is intended only for the person or entity to which it
is
, lhc
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information transmitted is confidential and may be proprietary to FOX
Systems, Inc. It is intended only for the person or entity to which it
is addressed. Anyone else is prohibited from disclosing, copying, or
disseminating the conten
ation, if any provider can simply
decide that in their opinion someone is receiving too much medication or
is trying to buy drugs for illicit purposes, etc. and because of that,
they can broadcast any PHI to any or all providers in a given community
(or state, or?).
Regards, lhc
Leah Hole-
ical exam first), and in this case the provider
could share the results of the physical exam, but they would have to
have the authorization that the life insurance company obtained first.
see 164.508(b).
Regards, lhc
Leah Hole-Curry, JD
FOX Systems, Inc.
602.708.1045
Information transmitted is confi
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