Re: Self insured health plans NPP

2003-03-13 Thread David Blasi
Without going into a lot of discussion about the difference between the plan sponsor and plan administrator activities, the plan administrator is responsible for this. If you are also the plan administrator, than you have both responsibilities. Your SPD should state who is the plan

Pharmacy and NPP

2003-03-13 Thread Ken Kupetsky
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

RE: Pharmacy and NPP

2003-03-13 Thread Bentz-Miller, Judith
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

Re: Facility Directory

2003-03-13 Thread Doug Webb
Donald, I agree with your opinion that you don't have to ask, but a check-off line in the sign-in form would be nice. It would also document that the option had indeed been offered, and since, in this game, documentation is everything, that would be a Good Thing. The opinions expressed here

RE: Facility Directory

2003-03-13 Thread Ribelin, Donald
Doug, while I agree it would be nice; I tend to doubt this will be the common practice. Asking every admission if they want to opt-out of the facility directory would be costly. We (providers) are already concerned about the costs (in time and money) we will incur secondary to the distribution

policy dev for clearinghouse

2003-03-13 Thread rachelmcass
Another clearinghouse question 164.506 (c)(4) states that (paraphrased): 'A covered entity may disclose protected health information to another covered entity for health care operations of the entity that receives the information, if both covered entities has or had a relationship with the

Disclosure records vs. record retention

2003-03-13 Thread Gerry Friberg
We are a covered entity as a clearinghouse. We are also a business associate to medical providers. The rules require keeping records of disclosures outside of TPO for six years. At termination of business associate agreement the rules require return or destruction of all PHI if feasible. How

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 ofand obtain the individual's oral agreement or objection to a use or disclusire permitted by this section". In the

Security Requirements

2003-03-13 Thread Daryn Thompson
In the final security document, you have standards. Some standards have implementation specifications and others do not. On the standards that do have them, they are REQUIRED or ADDRESSABLE. On the ones that do not have specifications, are they Required? Daryn Thompson Network/I.S.


2003-03-13 Thread JillGWlaw
I understand that you do have to ask a patient if they wish to have the clergy receive their names in the directory; however, does the same requirement apply if the clergy member is a member of the covered entity's workforce, like a chaplain of a hospital? --- The WEDI SNIP listserv to which

Re: Self insured health plans NPP

2003-03-13 Thread John J. D'Amato
Hi, David and Bonnie. It's important to keep two terms distinct: plan administration functions (which is a Privacy Rule term) and plan administrator (which is an ERISA term). The plan administrator (which, under ERISA, is the plan sponsor unless the plan document says otherwise) has certain

RE: Security Requirements

2003-03-13 Thread Christiansen, John (SEA)
Not that knowing that is much help in figuring out what you need to do . . . John R. Christiansen Preston | Gates | Ellis LLP 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104 (Direct: 206.370.8118 (Cell: 206.683.9125 * [EMAIL PROTECTED] Notice: Internet e-mail is inherently

Filing deadline for complaints

2003-03-13 Thread Diana DeWeese
Regarding complaints filed with the Secretary of DHHS, the Privacy Rule states in 160.306 (b)(3) that a complaint must be filed within 180 days of when the complainant knew or should have known. Can a covered entity specify a shorter time frame for an individual filing a complaint with the

A tricky BA Questions

2003-03-13 Thread Vikas Budhiraja
I have been encountered with a tricky BA question and hope someone can provide some insight. Insurance companies engage certain agencies to audit provider records to verify if what the hospital billed was correct and if the insurance company has overpaid. Since these audit agencies are engaged by

Re: Security Requirements

2003-03-13 Thread Doug Webb
Daryn, Yes. The opinions expressed here are my own and not necessarily the opinion of LCMH. Douglas M. WebbComputer System EngineerLittle Company of Mary Hospital Health Care Centers[EMAIL PROTECTED] "This electronic message may contain information that is confidential and/or legally

Re: Self insured health plans NPP

2003-03-13 Thread Sue Ryan
John, In your explanation, you state that if you are a self-insured plan and you contract out EVERYTHING to a third party administrator (TPA), you are not spared ANY of the requirements of the Privacy Rule. You must still prepare and distribute an NPP to your participants and satisfy all of the

PRIVACY: BA Agreements

2003-03-13 Thread Deborah Campbell
Title: PRIVACY: BA Agreements I have drafted a BA Addendum and a BA Agreement. We will use the addendum with anyone we have a contract with. However, there are certain entities that do fee-for-service for us and do not have contracts (printing companies, lawyers, temp agencies, etc.) For

Re: Self insured health plans NPP

2003-03-13 Thread John J. D'Amato
Hi, Sue. What I meant by my comment is that a group health plan's relationship to a health insurance issuer and its relationship to a TPA are associated with radically different legal responsibilities under the Privacy Rule, even where the two relationships are functionally equivalent. This is

Re: Self insured health plans NPP

2003-03-13 Thread John J. D'Amato
Hi, John. The way I read the Privacy Rule, a plan sponsor that self-insures will always bear the ultimate responsibility for complying with the Privacy Rule and will not be treated as functionally equivalent to a plan sponsor that insures benefits, even if the self-insuring plan sponsor

RE: Security Requirements

2003-03-13 Thread Rachel Foerster
Title: Message Yes Rachel Foerster Rachel Foerster Associates, Ltd. Voice: 847-872-8070 email: [EMAIL PROTECTED] # This transmission may be confidential or protected from disclosure and is only for