I think you would
have to train a temporary workforce member just as you would a workforce
member that was not temporary. My understanding is you don't train
on the privacy rule itself, you train on what procedures/policies that all
employees need to know about your privacy procedures, tha
Doug,
Why do you suggest "If you need a separate Authorization to do the
disclosure, log it". Refer to § 164.528(a)(1)(iv)
The rule says:
Right to an Accounting of Disclosures of Protected Health Information - §
164.528(a)
1. An individual has a right to receive an accounting of disclosures of
p
Doug,
Thanks for the clairication for your organization.
Since the Privacy Rule requires we "document and retain any signed
authorization as required by § 164.530(j)".."for six years from the date of
its creation or the date when it last was in effect, whichever is later", we
have elected to st
Title: Message
I don't think saying a CE
"may not use or disclose protected health information in a manner inconsistent
with such notice" is the same as "if you notice a patient regarding a disclosure
that is permissible means that you do not need to account for it". My
beliefs are based on
Title: Message
Do you
have HHS commentary that states if 'a disclosure allowed by law if it
is addressed in your notice of privacy practices doesn't have to be
accounted for'? If so please let me know where to find it. If there
is supporting commentary then it would make a lot of health ca
Title: Message
Cindy,
The key work here is
incidential. I don't feel this would be an incidential disclosure
since you know the cleaning folks will have access to PHI. See text below
from another list about the topc.
Date
1/16/03
"...yesterday during a
conference call with 2,000 plus
Title: Message
Cheri,
My position is
this situation is not an incidential disclosure, do you disagree with
that? It was Linda Sanchez of DHHS that said a BAA was
needed.
Like you, my concern is
also the stipulation of your quoted text that "provided reasonable safeguards
are in place."
There are very different NPP requirements
for a health plan and a health care provider. While a health care
provider has a requirement to obtain a written acknowledgment of receipt, a
health care plan does not. I refer to Provision of Notice of Privacy
Practices - § 164.520(c) below:
HH
Title: Message
Dennis,
I am not sure where
your disagreement exists with me since I did not say they are a business associate.
It was a DHHS member that said "if you know that a repairperson *WILL*
have access to PHI as part of her/his job to repair something, then that is not
an incident
Thank you for your input. I agree 100% with you. Do you mind if I
privately share your response with the person that misquoted Ms. Sanches's
response? I hate for her to be misquoted. The person may want to recheck
their notes and post a correction to the other list where they quoted her.
Cin
Matt,
Here is the source of my confusion, thank you in advance for any light you
can shed on my question. We have an open filing system for our medical
records, so are unable to better safeguard them. Budget constraints
prohibit a more secure system at this time. When our contract cleaning folks
Diane,
If you limit your complaint acceptance period to 30 days, the only other
recourse the person would have is to file a complaint with the Secretary if
the occurance is more than 30 days old. For my agency, I had rather our
patients come to us with a complaint rather than the Secretary of DHH
Limited English Proficiency (LEP) guidance at:
http://www.hhs.gov/ocr/lep/
If you are subject to Title VI, as it applies to LEP persons, below is safe
harbor gudiance from the above OCR resource:
Safe Harbor. The following actions will be considered strong evidence of
compliance with the recipie
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