RE: who holds the power?

2003-01-24 Thread Bentz-Miller, Judith
I strongly agree also. If there is no BAA in place, or not a well written one in place, it is the CE who will be audited and suffer the consequences under HIPAA and the OCR. we will also suffer the consequences in the press if one of our vendors has a huge faux-pas with PHI that the CE has

RE: NPP and illiterate population

2003-01-24 Thread Bentz-Miller, Judith
We will be RECORDING it as a voice mail message (our system handles over 12 minutes!) and having an extension, with access on both the local line and 800 line. We are also having a privacy (800 number) hotline set up and both numbers will be listed on business cards. Business cards will be

RE: What PHI to give out to callers?

2003-01-30 Thread Bentz-Miller, Judith
We are working on having an authorization that will cover these "gray areas". It will follow the guidelines with HIPAA and allow us to share information with anyone the patient wishes to be involved in their care. It will only be valid for a year, and the patient will be able to revoke it

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

Sharing information with clinic owned HMO

2003-02-20 Thread Bentz-Miller, Judith
I need some feedback regarding how others CEs are handling the following scenario: We are a clinic that has an HMO. Technically, it is a department of the clinic, but we have separate ourselves into two different CEs. In the past, we have allowed the HMO staff to have access to our database and

RE: PHI In Mail

2003-02-28 Thread Bentz-Miller, Judith
Title: Glacier Lee, weplace it inside of the patient'smedical records so when we see the patient again, we can hand it to them and get a new address. Note that the unreturned mail isNOT part of our Designated Record Set, since it is a duplicate of a part of the DRS. (billing, lab results,

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: New to this list, have two questions.

2003-03-24 Thread Bentz-Miller, Judith
Title: RE: New to this list, have two questions. This was part of our privacy audit due to the following reg: ยง 164.530 Administrative requirements. (c) (1) Standard: safeguards. A covered entity must have in place appropriate administrative, technical, and physical safeguards to protect

RE: Separating financial and clinical data

2003-03-27 Thread Bentz-Miller, Judith
I respectfully disagree regarding the information being kept separate regarding the INSURANCE CARDS. With different plans, different rules, etc... this is a major player with the clinicians, especially nurses, who are scheduling tests, precerts, etc... They have to know what kind of plan, which

RE: NPP distribution

2003-04-02 Thread Bentz-Miller, Judith
In regs 164.520 it states"No later than the date of the first service delivery, including service delivered electronically, to such individual after the compliance date for the covered health care provider;So it is a combo of the two of them. Receive NPP and sign acknowledgement no later

Requiring picture ID

2003-10-29 Thread Bentz-Miller, Judith
We are a large multi-specialist clinic and we are in the process of doing a risk assessment for requesting picture ID for each visit. Can you let me know: Do you currently request picture ID at check in? Do you keep a copy of it, electronic or paper? Why do you or do not request positive ID?

RE: Amendment to DRS

2003-11-10 Thread Bentz-Miller, Judith
I believe the patient can REQUEST any information in the DRS be changed, regardless of date. (You may be thinking of the accounting of disclosure, which does have a pre 4/15/03 exception.) However, you are NOT OBLIGATED to accept an amendment. If you cannot corroborate it, I would deny it and