RE: Facility Directory

2003-03-13 Thread Rupe, Cindy



"164.510 - Uses and disclusres requiring an opportunity 
for the indiviudal to agree or to object " .  The citation even says that 
"the entity may orally inform the individual of and obtain 
the individual's oral agreement or objection to a use or disclusire permitted by 
this section".  In the Preamble it states three conditions under which a 
patient can be listed in the directory, 1. the NPP is given; 2. they give the 
patient a meaningful opportunity to opt out of the directory or to 
restrict all or some of the uses and disclosures in the directory; 3. pt. 
does not object to being in the directory.  (this is on page 82521of the 
Dec 28, 2000 Fed Reg)  Seems to me (IMHO) that this is part of the 
dialog registration will have to have with the patient, not just the patient 
reading the NPP.  Thanks Cindy
 

Cindy Rupe, RHIA, CPHQ HIPAA Coord/Consultant 406-247-7161 [EMAIL PROTECTED] 
HIPAA Ready, HIPAA 
Compliant, and HIPAA Aware 

  -Original Message-From: KERBER, JEFF 
  [mailto:[EMAIL PROTECTED]Sent: Thursday, March 13, 2003 7:59 
  AMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: 
  Facility Directory
  In 
  reading the other responses to this, I'm shocked admissions isn't already 
  doing this in most facilities. In the many discussions I have had with other 
  hospitals the question on this has never been do we have to even tell them of 
  the option. The question has always been how will this change what we ask (ie, 
  clergy).  Most hospitals do this as part of JCAHO standards R.1.3.1, 
  R.1.3.2, R.1.3.1, R.1.3.6.1 and R.1.3.6.1.1
   
  That 
  said... while you aren't required to tell them when they are admitted. 
  Shouldn't you? Think about it. How many patients are going to sit and read 
  your 3-8 page NPP and let you know they want to opt-out of the directory? This 
  is a question of doing the right thing.
  
-Original Message-From: Cindy Stroud 
[mailto:[EMAIL PROTECTED]Sent: Wednesday, March 12, 2003 
6:54 PMTo: WEDI SNIP Privacy Workgroup ListSubject: 
Facility Directory
For some reason I have been under the 
assumption that when a patient registers we, an acute care hospital, need to 
explain the right to opt-out of the facility directory. Is this something we 
need to explain verbally or is the fact that explanation in the NPP is 
sufficient? I really appreciate any feedback
Cindy---The WEDI SNIP listserv 
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RE: Unlocked charts

2003-03-07 Thread Rupe, Cindy
Title: Message



The 
OCR guidance states that a BA is not required:
 
With 
persons or organizations (e.g. janitorial sercie or electrician) whose functions 
or services do not involve the use or disclosure of protected health 
information, and where any access to protected health information by such 
persons would be incidental, if at all.
 
Thanks, Cindy

Cindy Rupe, RHIA, CPHQ HIPAA Coord/Consultant Billings Area 
IHS 406-247-7161 [EMAIL PROTECTED] 
HIPAA Ready, HIPAA 
Compliant, and HIPAA Aware 

  -Original Message-From: 
  [EMAIL PROTECTED] 
  [mailto:[EMAIL PROTECTED]Sent: Friday, March 07, 2003 
  10:15 AMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: 
  Unlocked charts
  This 
  was brought up in San Diego by the folks from OCR.  One of them said her 
  owned doctor accused her of being "one of those people who are making us put 
  locks on our file cabinets."  She stated that the requirement is to keep 
  the PHI private.  If the file cabinet is in a patient area, it might be 
  wise to lock it.  If it is out of a public area, the location may be all 
  that is needed to keep it private.
  *The 
  cleaning company should sign a BAA.
   
  
  Joanne 
  Marquez
  Senior Director 
  
  Beech Street 
  Corporation
  Account 
  Services
  (949) 
  672-1519
   
  

-Original Message-From: 
[EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Sent: 
Thursday, March 06, 2003 7:06 PMTo: WEDI SNIP Privacy Workgroup 
ListSubject: Unlocked chartsThis has probably been covered before, but for those of 
us still not clear:Do charts have to locked up if they are within 
the area of the practice to which no one but employees who may need them 
have access? The cleaning crew would be in the same area at night. 
Thanks very much.Vicki SaundersPain Clinic Associates, 
PC[EMAIL PROTECTED]Pain Clinic Associates, PC 
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