Patients have the right to inspect and copy their medical record a practice maintains in a designated record set. I understand that some offices keep internal notes of sorts (this patient is difficult, cooperative, etc.). Do patients have the right to access those as well? Are they considered part
I have a line that states "I acknowledge receipt of the Notice of Privacy
Practice." and a line to sign on our COA. I'm going to piggyback a question
with your question, are initials acceptable for acknowledgment?
-Original Message-
From: Craig Moen [mailto:[EMAIL PROTECTED]
Sent: Tuesday
During our initial admit paperwork we are planning of having the patient
initial next to acknowledgement of receipt. However, they also sign the end
of that document because they initial other items on that particular page
For existing patients, I don't see how intials by themselves would work
J
Craig,
I agree with your position. I think that a signed
document needs at least one full signature. Having that full signature and
date, I would think that initials other places should be OK (they work for the
money people).
The opinions expressed here are my own and not necessarily the
Doug
and Leslie
As I
was looking into the Rule itself for something different I stumbled across this
under 164.522 pg 53240
"For
example, The final rule does not require an individuals signature on the
notice. Instead, a covered healthcare provider is permitted, for example
to have the
According to the regs, if the patient has not submitted a written statement of disagreement when a covered entity denies their request for an amendment, the covered entity must include the patient's request for an amendment and its denial of it with any subsequent disclosure of the PHI only if the
I’ve also seen small practice groups
(in lieu of “sign in sheets”) and pharmacies developing an “acknowledgment
book” approach with the printed language of the acknowledgment at the top
of each page with patients signing the book and dating their signature and it
is my understanding that t
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
A very good question that I am also interested in finding others opinions
At this point we are going to log "non-routine" requests (such as someone
that was not originally identified and is now requesting info, even if the
family agrees/consents) Also we are logging errors such as missent faxes
a
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
Am I clear in my understanding that for a physician to release phi in situations such as employment physicals, school nurse (return to school), immunization records for schools or camp physicals that he/she would need a signed authorization? Can anyone direct me to some written guidance on this?
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]
Confidentia
I
wanted to get input regarding Billing Services that use contractors to perform
certain services. My understanding is the Billing Service is considered a
Business Associate and not a covered entity. If that is true, would the
contractors working for a billing service be Business Associat
Daniel,
1) Billing Services are Business Associates of
Providers. Because of what they do, if they work with standard
transactions, they may also be considered a Covered Entity Clearinghouse
(converting [highly] non-standard data to standard transactions, and vice
versa).
2) An entity tha
Welcome to the wonderful world of confusion! Your understanding that a billing
service is not considered a covered entity MAY be incorrect. As a billing company, we
have struggled with the clearinghouse 'definition'.
If you are not considering yourselves a covered entity, as a business asso
Leslie -
So if my billing company did not consider itself a clearinghouse (thus a CE); and we
were only a BA, then anybody we subcontracted to would require us to have a BA as
well, (e.g. 'second tier business associates')? I have not seen/been told that
before. Please indicate where that is
Daniel:
Not all billing services are “business
associates” only. If your
billing service performs any “translations” of standard to
nonstandard data elements in connection with any of the standard transactions (e.g.,
if you receive any print images of non standard itemized bills your p
Daniel,
I
believe that your Billing Service would most likely be a BA, but check to
make sure you're not conducting standard transactions because that could make
you a Covered Entity...but that's a whole other issue.
I'm disturbed that your attorney is confused on this
issue. One of the
See 45 CFR Section 164.504(e)(2)(i)(D). There is also language to this
effect in the OCR's "Model" BA document.
Leslie Bender
-Original Message-
From: Brenda K. Burton [mailto:[EMAIL PROTECTED]
Sent: Wednesday, March 19, 2003 2:09 PM
To: [EMAIL PROTECTED]
Cc: [EMAIL PROTECTED]
Subject:
Yes.
We do
this all the time. Internally we refer to these as subcontractor business
associates. We have a template called a c-BAA that we have sent to all out
subcontractors based on the provision in the BAA that requires us to pass
through the same requirements to any subcontractor.
Th
Oops - my apologies - little typo - 45 CFR Section 164.504(e)(2)(ii)(D)
- need stronger reading glasses.
Leslie Bender
-Original Message-
From: Leslie C Bender [mailto:[EMAIL PROTECTED]
Sent: Wednesday, March 19, 2003 2:31 PM
To: '[EMAIL PROTECTED]'
Cc: '[EMAIL PROTECTED]'
Subject: RE:
Yes, thanks, I am familiar with that:
164.504(e)(2)(ii)(D)
"Ensure that any agents, including a subcontractor, to whom it provides protected
health information received from, or created or received by the business associate on
behalf of, the covered entity agrees to the same restrictions and con
If we do need an auth to disclose information to a school nurse such as immunizations or back to school note, what if the physician gives the completed form to the parent? He/she can disclose anything to the parent in the case of a minor? Would this replace the need for the authorization if we si
There
is a difference of opinions on the list servs.
Psychotherapy notes and the mental health records are two separate
things. Psychotherapy notes are the psychiatrists own personal notes they
keep in their office. Psychotherapy notes do not go into
the medical record. The notes that a
I would
disagree. I would think that you must account for WC disclosures that are
required by state law. However, many WC disclosures will not have to be
accounted for b/c they fall into the "payment" category which is an exception to
the accounting rule.
bob
coffield
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 Center Lane Woo
If the
internal notes are used in whole or in part to make a decision about an
individual, then they would be part of the DRS.
-Original Message-From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]Sent: Wednesday, March 19, 2003 7:44
AMTo: WEDI SNIP Privacy Workgroup ListSubject:
The intent of the "plain language" clause pushes us to implement procedures
to "educate" our patients about how we use and disclose their information,
and consequently, we encourage our clients (covered entities) to view
"reading level" as only one aspect. (BTW, this clause is applied to the
"auth
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