line and becomes a disclosure of PHI. Those pictures
should come down or have the patient sign an authorization.
Noel Chang
Integral Practice Solutions
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: "Oriol, Albert" <[EMAIL PROTECTED]
ortunately, that is
the only scenario they specifically address so I would infer from that that
any other service conducted by phone (such as refilling a prescription) would
require you to mail the NPP to the patient that day.
Noel Chang
Integral Practice Solutions
--
Open WebMail Pro
Sounds to me like you should treat them as a member of your workforce, which
I believe would obviate the need for a BAA.
Noel Chang
Integral Practice Solutions
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: "Traci Winter" <[EMAIL P
tions of the Rule for more reading on OHCA's:
Section 164.501 - Definition of an OHCA
Section 164.506(c)(5) - Disclosure of PHI for operations between members of
an OHCA
Section 164.520(d) - Joint notice by separate covered entities
Hope that helps,
Noel Chang
Integral Practice Solutio
now need
one set of charts for financial data that is not in software systems (e.g.
copies of insurance cards) and a separate set of charts for clinical data?
Someone please show me a convincing out!
Noel Chang
Noel Chang
Integral Practice Solutions
--
Open WebMail Project (http://openweb
know what people perceive to be the down side(s) of joining
an OHCA?
Thanks,
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: Kathy Findley <[EMAIL PROTECTED]>
To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTEC
ive) I think you will
be able to demonstrate good faith. If they don't agree, you will told to fix
it. Personally, I'd rather buy a bunch of locking cabinets or build "medical
records rooms" if they tell me I have to do it, but not before if I
reasonably believe the record
as to be, before OCR will come audit a covered entity remains to
be seen.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: "Patricia Conroe" <[EMAIL PROTECTED]>
To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PRO
disclosure. For example, as part
of a routine protocol, the name of the individual may be requested by the
payer as the minimum necessary to validate the identity of the claimant or
for drug interaction or other patient safety reasons."
Noel Chang
--
Open WebMail Project (http://
the third column). In
this discussion HHS notes that they DO NOT consider them to be Business
Associates of covered entities because they are not performing a function on
behalf of the CE, they are performing a function of their own in their
capacity as a financial institution.
Noel Chan
n that to fill in the blanks. And HIPAA does
require that the blanks be filled in! HIPAA does say the PHI has to specify
exactly what procedure the payment was for, or when the payment was due.
Just that it pertains to payment for services.
Noel Chang
--
Open WebMail Project (http://openwe
ll be using to provide a brief overview of
the subject before opening the subject to the other call participants.
I hope the call will be beneficial to all participants and I look forward to
hearing your questions and issues on the call.
Sincerely,
Noel Chang
--
Open WebMail Project
isclosures made among your own staff are for TPO and
therefore do not have to be accounted for. I cannot think of any other
requirement under the Rule to keep a list of everyone who views an
individual's PHI.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- O
bout the individual".
>
> So if someone claiming to be John Smiths grandson calls and asks if his
> gransfather is there and what is his general condition, you may release
> that. Anything more than that and I think you must verify to whom
> you are disclosing PHI as required in
oup practice
need to have less than 10 FTE's or less than 25 FTE's to qualify as a "small
provider"?
Thanks,
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
---
The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions
on this list
tion his grandfather should be
taking, as long as John Smith has received your NPP, has not objected to such
disclosure, and has identified his grandson as someone involved in his care,
you can disclose to the caller without doing anything to verify that he
really is John Smith's grandson.
G
I never thought the
requirement to distribute the NPP and obtain an acknowledgment would require
any additional resources like part time employees.
Noel Chang
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: [EMAIL PROTECTED]
To: "W
d not read into that overlap that ALL
disclosures addressed in the NPP are exempt from accounting.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: "Halterman, Anita" <[EMAIL PROTECTED]>
To: Noel Chang <[EMAIL PROTECTED]>,
would not have to be
accounted for.
Of course, if the audit is for your own purposes, why are you disclosing the
audit information to anyone outside the provider's office (unless you are
using a business associate to perform the audit for you).
Noel Chang
--
Open WebMail Project (ht
that by mentioning a type of disclosure in my NPP I can
then claim it is part of TPO? I don't see any room to make that argument
since TPO is clearly defined in sections 164.501 and 164.506.
Thanks,
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original
by section 164.506. Since they are TPO, no
accounting is necessary.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: Beth Cole <[EMAIL PROTECTED]>
To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]>
Sent: Thu, 13
viders for treatment purposes, or
disclosure between a provider and a health plan for payment purposes. In
either scenario, no BA relationship exists.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: "Kristen Emerson" <[EMAIL PRO
to be accounted for for some other
reason, I'd love to hear it.
I appologize if my earlier anwers were incorrect or misleading. Thanks for
pointing out my mistake.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: "Traci.Jens
ey bill to and the cilling company are each
> > performing their own discrete step in the paymeny process. Neither is
> > performing any function on behalf of the other.
> >
> > Noel Chang
> >
> > --
> > Open WebMail Project (http://openwebmail.org)
&g
ount for such disclosures. The disclosures that
should and should not be accounted for are ennumerated clearly in section
164.528(a)(1). I am not aware of any relief from these requirements through
your NPP.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Messa
lly responsible party who is not the same person as the
subject of the PHI.
BA agreements are only necessary when you have a third party performing a
covered function on your behalf.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From
. The key here is who is performing functions on behlaf of whom? The
clearinghouse is providing billing services on behalf of the provider. The
provider is not doing anything on behalf of the clearinghouse.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Origin
. Neither is
performing any function on behalf of the other.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: [EMAIL PROTECTED]
To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]>
Sent: Tue, 04 Feb 2003 12:11:22 -08
ransactions" refer to the Transaction and
Code Set Standards.
I would also note that the definition of conducting a
transaction "electronically" is often debated. I know HHS has indicated in
the preamble to the Privacy Rule that a fax does not count as electronic
transmission.
e document but I
do not necessarily have the authority to commit to that.
Thanks in advance for your responses,
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: "Shek, Molly" <[EMAIL PROTECTED]>
To: "WEDI SNIP Privac
and in the December guidance issued by OCR. I'm sure I
could cite you the exact source if you have trouble convincing your other
committee members.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: "Traci Winter" <[EMAI
to de-identify the information in the first place!
Please explain your situation better and please give specific citations as to
where you think there are conflicts with the Privacy Rule. Otherwise I'm
afraid I don't understand the question well enough to offer an opinion.
N
recognized affiliation or relationship with my facility was
asking for disclosure, the safer course of action may be to deny access.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: Beth Cole <[EMAIL PROTECTED]>
To: "WEDI SNIP Privacy Wo
section
164.520(c)(2)(iv). I would also infer from the regs. that you are obliged to
post the updated version on you website, if you have one, but I cannot find
an explicit statement about this.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message
could track the individual
down through whoever faxed you the authorization and try to resolve the
conflict but you can see how that might become time consuming.
So is there a short answer? What trumps what? Authorizations or
restrictions on use and disclosure?
Noel Chang
--
Open WebMail Pr
the Transaction and Code Set Standards and would only be used
between parties that are conducting a covered transaction.
COT agreements I believe are a creature of the long awaited Security Rule and
since that is not finalized I don't think we can say if a COT is appropriate
or not.
Noe
sword protection you need
is again subject to what is reasonable for your circumstances.
Noel Chang
--
Open WebMail Project (http://openwebmail.org)
-- Original Message ---
From: "Ritter, Nicole" <[EMAIL PROTECTED]>
To: "WEDI SNIP Privacy Workgroup List" <[E
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If you need to unsubscribe but your current email address is not the same as the
addres
cost based" fee. I think it would be hard to explain how
other entities' fees have any bearing on what it costs you to produce a
copy. The section goes into further detail as to what may be included in
your costs, e.g. the cost of supplies and labor to produce the copies.
Noel Chang
o people agree or do they feel there are some hard and
fast rules concerning how the physical work space should be layed out?
Noel Chang
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