Ken,
I think you need to analyze how the pharmacy is legally set up at your
hospital.  We also have a pharmacy on-site, and while we treat it as any
other department internally, it legally is a separate company.  We
documented an Affiliated Covered Entity (ACE) between the two and listed
this in our NPP (along with two other companies.)  

Hope this helps
Judith

Judith Bentz-Miller
Privacy Officer
Arnett Clinic
765-448-8843


  

-----Original Message-----
From: Ken Kupetsky [mailto:[EMAIL PROTECTED]
Sent: Thursday, March 13, 2003 8:33 AM
To: WEDI SNIP Privacy Workgroup List
Subject: Pharmacy and NPP


We issue prescriptions to our employees and their families at the hospital
pharmacy. Do we need to list the pharmacy as a separate entity in our NPP or
not? There seems to be debate on how they should be categorized.



Ken Kupetsky
CIO/Chief Privacy Officer
Burke Rehabilitation Hospital
Office - 914-597-2202



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