Employee Access and Accounting of Disclosures

2003-11-01 Thread Walter Suarez
When an employee of a covered entity accesses PHI and it is determined that this was done wrongly (say, violating the minimum necessary requirements for that employee, or just plain inappropriate access someone's PHI by the employee), would this result in the employer having to log it into the

Re: Employee Access and Accounting of Disclosures

2003-11-01 Thread Ellen Rubin
Suarez [EMAIL PROTECTED] To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED] Sent: Saturday, November 01, 2003 5:06 AM Subject: Employee Access and Accounting of Disclosures When an employee of a covered entity accesses PHI and it is determined that this was done wrongly (say, violating

RE: Employee Access and Accounting of Disclosures

2003-11-01 Thread Matthew Rosenblum
Ellen, This is one of those HIPAA topics where we would advise hanging a large Proceed with Caution sign, and where we would welcome additional guidance from HHS. Section 164.528(a)(1)(iii) of the Privacy rules --Accounting of disclosures of protected health information-- notes that HIPAA does

HHS/OCR Guidance re Accounting of Disclosures required by law

2003-04-12 Thread Jim Moores
The National Association of Boards of Pharmacy requested guidance from OCRregarding the application of the accounting requirement to regulatoryinspections made by state boards of pharmacy and mandatory disclosures forcontrolled substance tracking. By way of background, pharmacies

FW: HHS/OCR Guidance re Accounting of Disclosures required by law

2003-04-12 Thread Catherine Erickson
Title: Message Can anyone help explain the paragraph in the OCR letter (last one on first page) that talks about not having to track disclosures individually? I am confused at the direction here. We are required to provide an accounting of disclosures with information on when the disclosure

Accounting of Disclosures - health care oversight

2003-04-03 Thread Shek, Molly
Message- From: Dean Cranwell [mailto:[EMAIL PROTECTED] Sent: Wednesday, April 02, 2003 8:40 AM To: WEDI SNIP Privacy Workgroup List Subject: RE: Accounting for Disclosures, and Health Oversight Rachel: I believe your thinking is correct. I attended the Regional HIPAA Conference sponsored

RE: Accounting for Disclosures, and Health Oversight

2003-04-02 Thread Shek, Molly
, RHIA -Original Message- From: rachelmcass [mailto:[EMAIL PROTECTED] Sent: Wednesday, April 02, 2003 7:43 AM To: WEDI SNIP Privacy Workgroup List Subject: Accounting for Disclosures, and Health Oversight I attended education yesterday for nursing facility providers, in which

RE: Accounting for Disclosures, and Health Oversight

2003-04-02 Thread Dean Cranwell
on Individual Rights noted that the nine disclosures permitted by the public policy exception to the Privacy Rule which included Health Oversight Activities must be included in an accounting of disclosures. Dean Cranwell Chief Privacy Officer American HealthCare, LLC 2965 Colonnade Drive, Suite 200 Roanoke

RE: Accounting for Disclosures, and Health Oversight

2003-04-02 Thread Huber, Cheri
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

RE: Accounting for Disclosures, and Health Oversight

2003-04-02 Thread Shek, Molly
Licensing activities are included in health care operations and health care operations do not have to be tracked for accounting of disclosures. I am just going by the regulations. I don't think that that is stretching it. Thanks. Molly Shek, MS, RHIA

Accounting of Disclosures, research with approval of IRB

2003-03-26 Thread Wesloh, Janelle
For research, we state in our Privacy Notice that we may use or disclose protected health information without pt consent or authorization if our research privacy board (IRB) approves a waiver of authorization for disclosure. So, do we then need to account for those disclosures in the accounting

RE: Accounting of Disclosures, research with approval of IRB

2003-03-26 Thread Colleen Rooney
Hi Janelle, In regards to your questions about the accounting of disclosures, waivers of authorization and research, the answer is YES. No accounting of disclosures for the following: - Limited data set disclosure for research - Deidentified information for research - Research conducted

Accounting of Disclosures

2003-03-19 Thread Patricia Conroe
I know this has been asked repeadetly, but now that I'm training our workforce I'm starting to get more detailed questions on what needs to be logged. As the HIPAA rule states it they say what does not have to be logged, but they don't say what does. So, by the process of elimination I'm left

RE: Accounting of Disclosures

2003-03-19 Thread Craig Moen
Subject: Accounting of Disclosures I know this has been asked repeadetly, but now that I'm training our workforce I'm starting to get more detailed questions on what needs to be logged. As the HIPAA rule states it they say what does not have to be logged, but they don't say what does. So

Re: Accounting of Disclosures

2003-03-19 Thread JillGWlaw
I understood that if you were disclosing PHI to worker's comp carriers for payment purposes, you would not have to include it in the accoutning of disclosures. Jill Rubin, Esq. (617)388-2404 [EMAIL PROTECTED] --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions

RE: Accounting of Disclosures

2003-03-19 Thread Dee Warrington
Jill -- Correct. You do not have to account for workers compensation disclosures. Dee Warrington Director, HIPAA and Regulatory Compliance OAO HealthCare Solutions, Inc. 20955 Warner Center Lane Woodland Hills, CA 91367 (818) 598-6606 Fax: (818) 598-3270 [EMAIL PROTECTED

RE: Accounting of Disclosures

2003-03-19 Thread Dee Warrington
Thanks for the clarification. I was only thinking of Workers Comp in terms of "payment", and yes, I agree, any disclosures outside of payment you would need an accounting. Dee Warrington Director, HIPAA and Regulatory Compliance OAO HealthCare Solutions, Inc. 20955 Warner C

RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Jason Brege
As a Business Associate collection agency, we have not had any Covered Entity clients request to track our disclosures themselves. The wording they have used inour contractsinstructs us to forward disclosure information if they notify us of an accounting request. What we are doing

Re: Tracking Disclosures by Business Associates

2003-03-11 Thread JillGWlaw
By the same token, for the patient accounting, would you have to include disclosures you make to business associates like transcription agencies and disposal agencies? They would come up very often... Jill Rubin, Esq. (617)388-2404 [EMAIL PROTECTED] --- The WEDI SNIP listserv to which you

RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Jason Brege
I'm not entirely sure who "you" is in your question, but I assumed that you are asking about business associates disclosing to business associates,so here's a stab at an answer. It might also apply if you're asking about CE disclosures to transcription/disposal agencies.

RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Joanne.Marquez
to be logged as disclosures. Joanne Marquez Senior Director Beech Street Corporation Account Services (949) 672-1519 -Original Message-From: Jason Brege [mailto:[EMAIL PROTECTED] Sent: Tuesday, March 11, 2003 7:32 AMTo: WEDI SNIP Privacy Workgroup ListSubject: RE

RE: Tracking Disclosures by Business Associates

2003-03-11 Thread Jason Brege
--Original Message-From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]Sent: Tuesday, March 11, 2003 11:18 AMTo: [EMAIL PROTECTED]; [EMAIL PROTECTED]Subject: RE: Tracking Disclosures by Business Associates Wouldn't disposal come under operations? We have a vendor who picks us l

Public Health Disclosures

2003-03-06 Thread Karen Williamson
When we are intervening in an event that threatens Public Health (eg, a restaurant employee who has HEP-A) it is most likely necessary that we disclose PHI (eg, tell the restaurant manager the name of the employee who has HEP-A). My reading of 160.203(c), as well as 164.512(b), permits this.

RE: Accounting of Disclosures

2003-02-25 Thread Noel, Linda A.
: Accounting of Disclosures Disclosures for TPO do not have to be included in the Accounting of Disclosures. Please review the following list and let me know if you intent to include these in your Accounting Of Disclosures and the reason for the exception. Thanks. Suspected abuse reporting Underage

RE: Tracking for Accounting of Disclosures

2003-02-20 Thread Shelly Wilson
Our organization has elected not to become affiliated at this time. Therefore, each entity will become responsible for tracking their own disclosures as well as responding to requests for restrictions. Unless you can purchase a tracking software, managing this would be very difficult and I am

RE: Tracking for Accounting of Disclosures

2003-02-20 Thread Bentz-Miller, Judith
So each of you will have your own NPP, policies, etc... You will track all separately? -Original Message- From: Shelly Wilson [mailto:[EMAIL PROTECTED]] Sent: Thursday, February 20, 2003 1:24 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: Tracking for Accounting of Disclosures Our

Tracking for Accounting of Disclosures

2003-02-18 Thread Owens, Kris
Title: Tracking for Accounting of Disclosures I am interested in how organizations that have multiple locations, or multiple legal entities are approaching the Tracking of Disclosures. Are you: 1. Using a manual solution such as spreadsheets or paper logs? 2. Building a solution

Re: Disclosures - NPP and tracking

2003-02-17 Thread Leah Hole-Curry
Teri, I also agree - these are separate requirements that are not mutually exclusive. A covered entity must meet all requirements, relevant to a particular use or disclosure: A covered entity must have a notice of privacy practices which lists relevant disclosures and examples, among other

Re: Disclosures

2003-02-17 Thread David Ermer
Teri -- You are overstating the accounting for disclosures requirenment. Under the modified final rule, the only disclosures that are subject to the accounting for disclosure under § 164.528 are most post-4/14/03 (but not all) disclosures that are made without an authorization under § 164.512 (e.g

RE: NPP and accounting for disclosures - was Medicare audits: op erations?

2003-02-14 Thread CBowman
authorizations in our records, thus serving as a reference to our diclosure if we ever desire to refer back to disclosures made based on an authorization. Cindi Bowman Quality and Compliance Coordinator Catawba County Health Department 828-695-5847 -Original Message- From: Doug Webb

RE: NPP and accounting for disclosures - was Medicare audits: op erations?

2003-02-14 Thread Halterman, Anita
Title: Message Read 45 164.502 uses and disclosures of protected health information: general rules:(i) "Standard: Uses and disclosures consistent with notice. A covered entity that is required by 164.520 [the section addressing the notice of privacy practices] to have a notice may no

RE: NPP and accounting for disclosures - was Medicare audits: op erations?

2003-02-14 Thread Halterman, Anita
Title: Message The disclosures I had referenced in my earlier email posting are permissible disclosures (disclosures for audit purposes are allowed by HIPAA). I did not mean to imply that all accounting can be avoided as the notice should address typical uses of PHI for a CE. In general

RE: Aaccounting for disclosures - required by law ( was Medicare audits: operations?)

2003-02-14 Thread Chris Brancato
Title: Message We may have come full circle with this discussion. I concur. Ive not read anything that makes me believe that releases required by law are treatment; payment or designated operations. Therefore, I think these releases must be accounted for. Here is a related

Re: Recording Disclosures (was BA Agreement Questions)

2003-02-10 Thread Doug Webb
Title: RE: Recording Disclosures (was BA Agreement Questions) I also agree with Carolyn. An external Auditor would be a BA if (and only if) YOU hired the firm to perform audits for YOUR business purposes, and the auditor had to access to PHI in order to perform the audits. Government

RE: Recording Disclosures (was BA Agreement Questions)

2003-02-07 Thread Matthew Rosenblum
Title: RE: Recording Disclosures (was BA Agreement Questions) Traci, I tend to view (at least some of) the audit activities performed by the State as being conducted on behalf of the CE-Health Plans (e.g., Medicaid) as opposed to the CE-providers.  As such, those State-conducted audit

RE: Recording Disclosures (was BA Agreement Questions)

2003-02-07 Thread Price, Carolyn
Title: RE: Recording Disclosures (was BA Agreement Questions) IMHO, the audits are being performed on behalf of the State, under federal guidelines, and the auditors are NOT business associates. Their audits are on behalf of the State and Federal governments (i.e. Medicaid), NOT on behalf

RE: Recording Disclosures (was BA Agreement Questions)

2003-02-06 Thread Traci.Jensen
Title: RE: Recording Disclosures (was BA Agreement Questions) I would like to introduce myself, as I am new to this listserv. I am the HIPAA Privacy Project Manager for a health plan in Illinois. Even though I am new to this listserv, several of your names are familar from the HIPAAlive

Recording Disclosures (was BA Agreement Questions)

2003-02-05 Thread Jim Moores
, is that disclosure of PHIto the state a part of TPO, since the insurance company doesn't have any choice in the matter? Can the same be said for all regulatory types of disclosures? All opinions expressed are my own and should not be construed to be Medical Mutual or Antares Management Solutions

RE: Accounting for disclosures

2003-01-28 Thread Lamb, Tina
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

RE: Accounting for disclosures

2003-01-28 Thread mstucky
Tina, I am glad to here that someone else is utilizing existing systems. I also have developed a database for tracking disclosures. We, however have identified areas that release info and those departments/areas will be given access to enter the disclosure by patient into the database. Thanks

RE: Accounting for disclosures

2003-01-28 Thread Shek, Molly
The American Health Information Management Association web site has some very good articles on Accounting of Disclosures and the Association also provides an Accounting of Disclosures Analysis grid. This is a very good tool to assist one in identifying the disclosures that do not require tracking

RE: Accounting for disclosures

2003-01-27 Thread JFulcher
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

Accounting for disclosures

2003-01-24 Thread Halterman, Anita
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

Disclosures of PHI to fully funded groups

2003-01-23 Thread Waterhouse, Melissa
I have a question regarding releasing PHI to fully funded groups. Are health plans considering releasing PHI to fully funded groups provided they have a signed certification on file or are plans only releasing summary/de-identified PHI to the fully funded groups and not using the

RE: Disclosures of PHI to fully funded groups

2003-01-23 Thread Deborah Campbell
on it is prohibited and may be unlawful. * -Original Message-From: Waterhouse, Melissa [mailto:[EMAIL PROTECTED]]Sent: Thursday, January 23, 2003 3:03 PMTo: WEDI SNIP Privacy Workgroup ListSubject: Disclosures of PHI

RE: Disclosures to Insurance Brokers

2003-01-21 Thread McCauley Margaret M
To: WEDI SNIP Privacy Workgroup List Subject: Disclosures to Insurance Brokers I am looking for citations from the Privacy rule that support the disclosure of PHI to Insurance Brokers when the member asks the broker to intervene on their behalf with the Health Plan or Group Health Plan. Assume