RE: NPP in Other Languages

2003-03-19 Thread Matthew Rosenblum
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
authorizations, as well.)

On Page 53241 of the Preamble to the (revised) Privacy rules HHS notes the
Department continues to believe strongly that promoting individuals'
understanding of privacy practices is an essential component of providing
notice to individuals.  Further, on Page 53219 HHS notes that the HIPAA
documents must be written in plain language so individuals can read and
understand its contents.  And still, in its recent guidance-report, OCR
says that a CE must maximize readability and clarity of the HIPAA
documents.

The concepts of readability and understanding are not new and pervade
many (other) Federal and State laws and accreditor standards that regulate
health care.

In NY the NYS DOH has issued a consumer advisory that states, Translations
and/or transcriptions of important hospital forms, instructions and
information must be provided to you if you feel you need them, and the NYS
State auditors enforce the regulations and intents.  Consequently, in NYC we
must provide some of our (clients') hospitals and ambulatory centers in
Brooklyn with translations in Russian, translations in Chinese in Manhattan,
and translations in Spanish are distributed throughout the five Burroughs;
translations in Hindi will be needed in Queens.

In addition to NY, a number of States have health or mental health laws that
mandate patient rights activities in hospitals, nursing homes, and similar
residences or institutions.  And these laws usually contain the language
understandable clauses regarding how we must provide information to the
patient.  One of the clearest examples of this language is Iowa State law
(Chapter 28) for all institutions --28.4(229) Patients’ rights for the
mentally ill:

In order to preserve the patients’ self-respect and dignity..The
patient shall be provided with complete and current information concerning
patient diagnosis, treatment and progress in terms and language
understandable to the patient.

The JCAHO, too, is definitely NOT silent on this matter.  Its Rights of
Individuals standards include a statement that the Individuals served have
a right to effective communication..Written information provided is
appropriate to the age, understanding, and language of the individual served
[and] The organization provides for interpretation (including translation
services) as necessary.

As a practical matter, we believe, and advise our clients accordingly, that
for most hospitals it will be the JCAHO or other Accreditor, NOT OCR, that
will provide the initial findings of how well the HIPAA rules have been met
by the hospital.
 
I hope that this helps.
 
Your questions are always welcome.
 
Matt
 
Matthew Rosenblum
Chief Operations Officer
Privacy, Quality Management  Regulatory Affairs
 
CPI Directions, Inc.
10 West 15th Street, Suite 1922
New York, NY 10011
 
(212) 675-6367
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-Original Message-
From: Charles H. Thulin [mailto:[EMAIL PROTECTED] 
Sent: Tuesday, March 18, 2003 8:10 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: NPP in Other Languages

John,

I don't agree that the plain language requirement of the privacy
regulations requires translation of the NPP into other languages.

In its discussion of the plain language requirement in the preamble to
the final privacy regulations DHHS notes that Title VI of the Civil
Rights Act -- a separate statute -- generally requires entities that
receive Federal financial assistance to provide material ordinarily
distributed to the public in the primary languages of persons with
limited English proficiency in the recipients' service areas, 65
Fed.Reg. 82461, 82549 (December 28, 2000),  thereby creating an
obligation in some cases -- for entities that are subject to Title VI --
to provide the HIPAA notice in non-English languages.  

Employer group health plans, for example, aren't subject to Title VI
(they don't receive Federal

RE: NPP in Other Languages

2003-03-18 Thread Line, Phyllis
Title: RE: NPP in Other Languages





We are translating our notice into Spanish. 


-Original Message-
From: Kathy Findley [mailto:[EMAIL PROTECTED]]
Sent: Monday, March 17, 2003 1:08 PM
To: WEDI SNIP Privacy Workgroup List
Subject: NPP in Other Languages



Hello All!
I don't belive it's required according to the regulations, however, what is
everyone doing about having a version of the NPP in Spanish or other
languages?
Kf


Kathy Findley
Coordinator - Information Services and HIPAA
St. Joseph's Hospital Health Center
Phone - (315) 448-6111
Beeper - (315) 467-4180
Text Page - [EMAIL PROTECTED]



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Re: NPP in Other Languages

2003-03-18 Thread Beth Cole
As are we.  We have a part-time professional translator on staff who 
is/will be translating all of our HIPAA-related patient correspondence 
for us.

Beth

Line, Phyllis wrote:

We are translating our notice into Spanish.

-Original Message-
From: Kathy Findley [mailto:[EMAIL PROTECTED]
Hello All!
I don't belive it's required according to the regulations, however, 
what is
everyone doing about having a version of the NPP in Spanish or other
languages?
Kf



--
Beth Cole
Information Services Support Specialist
Newman Regional Health
Emporia, Kansas


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They also are not intended to be used as a forum for personal disagreements or 
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Re: NPP in Other Languages

2003-03-18 Thread Sonya . Springer

This message is intended only for certain recipients and may be privileged
or confidential.  If you have received it in error,
please notify us and delete it without making or retaining a copy.

THIS IS NOT LEGAL ADVICE. PLEASE CONSULT YOUR OWN COUNSEL.

While HIPAA may not require the NPP or other important documents to be
provided in multiple languages, there are other laws to keep in mind. Title
VI of the Civil Rights Act requires entities receiving federal funds to
provide reasonable accommodations to those who are are limited English
proficient (LEP). This includes providing translation of important
documents and interpreters. Each Federal agency is coming up with its own
guidelines.  DHHS has guidelines. You may want to check the LEP website
www.LEP.gov.
___
Sonya L.C. Springer
Assistant City Solicitor
Commercial Law Unit
City of Philadelphia Law Dept.
1515 Arch Street, 17th Fl.
Philadelphia, PA 19102

PLEASE NOTE THE  NEW PHONE NUMBER
Direct dial (215) 683-5051
Fax (215) 683-5069


   

Kathy Findley  

[EMAIL PROTECTED]   To: WEDI SNIP Privacy Workgroup 
List  
jhsyr.org  [EMAIL PROTECTED]  
   cc: 

03/17/2003 02:07   Subject: NPP in Other Languages 

PM 

Please respond 

to Kathy Findley   

   

   





Hello All!
I don't belive it's required according to the regulations, however, what is
everyone doing about having a version of the NPP in Spanish or other
languages?
Kf

Kathy Findley
Coordinator - Information Services and HIPAA
St. Joseph's Hospital Health Center
Phone - (315) 448-6111
Beeper - (315) 467-4180
Text Page - [EMAIL PROTECTED]


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discussions on this listserv therefore represent the views of the
individual participants, and do not necessarily represent the views of the
WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official
opinion, post your question to the WEDI SNIP Issues Database at
http://snip.wedi.org/tracking/.   These listservs should not be used for
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services.  They also are not intended to be used as a forum for personal
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you wish to receive an official opinion, post your question to the WEDI SNIP Issues 
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They also are not intended to be used as a forum for personal disagreements or 
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Re: NPP in Other Languages

2003-03-18 Thread David Ermer
It strikes me as an attorney who represents ERISA governed health plans
that the NPP can be considered a material modification to the health
plan under the U.S. Labor Department's (DOL) rules. DOL, in contrast to
HHS, has very specific rules on distributing a summary plan description
or a summary of material modifications to a plan participant, i.e., hand
delivery, first class mail (second or third class only if return and
forwarding postage is guaranteed and address correction is requested),
or electronic delivery under certain circumstances and on when you need
to translate such plan documents into another language. If your covered
entity is governed by ERISA, I suggest that you apply these rules. If
you covered entity is not governed by ERISA, you still may find the
guidance helpful. I have quoted the foreign language and mailing
guidance below. Best regards, Dave Ermer

29 C.F.R. §2520.102-2 Style and Format of SPD:

(c) Foreign languages. In the case of either--
(1) A plan that covers fewer than 100 participants at the beginning

of a plan year, and in which 25 percent or more of all plan
participants 
are literate only in the same non-English language, or
(2) A plan which covers 100 or more participants at the beginning
of 
the plan year, and in which the lesser of (i) 500 or more participants,

or (ii) 10% or more of all plan participants are literate only in the 
same non-English language, so that a summary plan description in
English 
would fail to inform these participants adequately of their rights and

obligations under the plan, the plan administrator for such plan shall

provide these participants with an English-language summary plan 
description which prominently displays a notice, in the non-English 
language common to these participants, offering them assistance. The 
assistance provided need not involve written materials, but shall be 
given in the non-English language common to these participants and
shall 
be calculated to provide them with a reasonable opportunity to become 
informed as to their rights and obligations under the plan. The notice

offering assistance contained in the summary plan description shall 
clearly set forth in the non-English language common to such 
participants offering them assistance. The assistance provided need not

involve written materials, but shall be given in the non-English 
language common to these participants and shall be calculated to
provide 
them with a reasonable opportunity to become informed as to their
rights 
and obligations under the plan. The notice offering assistance
contained 
in the summary plan description shall clearly set forth in the non-
English language common to such participants the procedures they must 
follow in order to obtain such assistance.

Example. Employer A maintains a pension plan which covers 1000 
participants. At the beginning of a plan year five hundred of Employer

A's covered employees are literate only in Spanish, 101 are literate 
only in Vietnamese, and the remaining 399 are literate in English. Each

of the 1000 employees receives a summary plan description in English, 
containing an assistance notice in both Spanish and Vietnamese stating

the following:
``This booklet contains a summary in English of your plan rights
and 
benefits under Employer A Pension Plan. If you have difficulty 
understanding any part of this booklet, contact Mr. John Doe, the plan

administrator, at his office in Room 123, 456 Main St., Anywhere City,

State 20001. Office hours are from 8:30 A.M. to 5:00 P.M. Monday
through 
Friday. You may also call the plan administrator's office at (202)
555-
2345 for assistance.''

29 C.F.R §2520.104b-1 Disclosure

(a) General disclosure requirements. The administrator of an 
employee benefit plan covered by part 1 of title I of the Act must 
disclose certain material, including reports, statements and documents,

to participants and beneficiaries. Disclosure under part 1 takes three

forms. First, the plan administrator must, by direct operation of law,

furnish certain material to all participants covered under the plan and

beneficiaries receiving benefits under the plan (other than 
beneficiaries under a welfare plan) at stated times or if certain
events 
occur. Second, the plan administrator must furnish certain material to

individual participants and beneficiaries upon their request. Third,
the 
plan administrator must make certain material available to participants

and beneficiaries for inspection at reasonable times and places.
(b) Fulfilling the disclosure obligation. (1) Where certain 
material, including reports, statements and documents, is required
under 
part 1 of the Act and this part to be furnished either by direct 
operation of law or on individual request, the plan administrator
shall
use measures reasonably calculated to ensure actual receipt of the 
material by plan participants and beneficiaries. Material which is 
required to be furnished to 

RE: NPP in Other Languages

2003-03-18 Thread Christiansen, John (SEA)
Folks -

The plain language requirement for the NPP incorporates regulatory
requirements that include translation into other languages if they are a
material element of the population you serve. I did the research well over a
year ago so don't recall the citations, and don't have time to dig it up
just now, but I believe it was available via an OCR webpage. There are
criteria for determining what languages you need to include, and this would
apply to any CE, not just an employer plan.

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 insecure. Unencrypted e-mail may be
accessible to unauthorized viewers, content may be modified or corrupted,
and headers or signatures may incorrectly identify the sender. If you wish
to confirm this message or the identity of the sender, please contact me
using a communications channel other than a reply to this e-mail. Secure
electronic messaging is available and recommended for confidential or
sensitive communications.


-Original Message-
From: David Ermer [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 18, 2003 1:53 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: NPP in Other Languages


It strikes me as an attorney who represents ERISA governed health plans
that the NPP can be considered a material modification to the health
plan under the U.S. Labor Department's (DOL) rules. DOL, in contrast to
HHS, has very specific rules on distributing a summary plan description
or a summary of material modifications to a plan participant, i.e., hand
delivery, first class mail (second or third class only if return and
forwarding postage is guaranteed and address correction is requested),
or electronic delivery under certain circumstances and on when you need
to translate such plan documents into another language. If your covered
entity is governed by ERISA, I suggest that you apply these rules. If
you covered entity is not governed by ERISA, you still may find the
guidance helpful. I have quoted the foreign language and mailing
guidance below. Best regards, Dave Ermer

29 C.F.R. §2520.102-2 Style and Format of SPD:

(c) Foreign languages. In the case of either--
(1) A plan that covers fewer than 100 participants at the beginning

of a plan year, and in which 25 percent or more of all plan
participants 
are literate only in the same non-English language, or
(2) A plan which covers 100 or more participants at the beginning
of 
the plan year, and in which the lesser of (i) 500 or more participants,

or (ii) 10% or more of all plan participants are literate only in the 
same non-English language, so that a summary plan description in
English 
would fail to inform these participants adequately of their rights and

obligations under the plan, the plan administrator for such plan shall

provide these participants with an English-language summary plan 
description which prominently displays a notice, in the non-English 
language common to these participants, offering them assistance. The 
assistance provided need not involve written materials, but shall be 
given in the non-English language common to these participants and
shall 
be calculated to provide them with a reasonable opportunity to become 
informed as to their rights and obligations under the plan. The notice

offering assistance contained in the summary plan description shall 
clearly set forth in the non-English language common to such 
participants offering them assistance. The assistance provided need not

involve written materials, but shall be given in the non-English 
language common to these participants and shall be calculated to
provide 
them with a reasonable opportunity to become informed as to their
rights 
and obligations under the plan. The notice offering assistance
contained 
in the summary plan description shall clearly set forth in the non-
English language common to such participants the procedures they must 
follow in order to obtain such assistance.

Example. Employer A maintains a pension plan which covers 1000 
participants. At the beginning of a plan year five hundred of Employer

A's covered employees are literate only in Spanish, 101 are literate 
only in Vietnamese, and the remaining 399 are literate in English. Each

of the 1000 employees receives a summary plan description in English, 
containing an assistance notice in both Spanish and Vietnamese stating

the following:
``This booklet contains a summary in English of your plan rights
and 
benefits under Employer A Pension Plan. If you have difficulty 
understanding any part of this booklet, contact Mr. John Doe, the plan

administrator, at his office in Room 123, 456 Main St., Anywhere City,

State 20001. Office hours are from 8:30 A.M. to 5:00 P.M. Monday
through 
Friday. You may also call the plan administrator's office at (202)
555-
2345 for assistance.''

29 C.F.R

RE: NPP in Other Languages

2003-03-18 Thread CBowman

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 recipient's written-translation obligations: 

(a) The DOJ recipient provides written translations of vital documents for
each eligible LEP language group that constitutes five percent or 1,000,
whichever is less, of the population of persons eligible to be served or
likely to be affected or encountered. Translation of other documents, if
needed, can be provided orally; or 

(b) If there are fewer than 50 persons in a language group that reaches the
five percent trigger in (a), the recipient does not translate vital written
materials but provides written notice in the primary language of the LEP
language group of the right to receive competent oral interpretation of
those written materials, free of cost. 

These safe harbor provisions apply to the translation of written documents
only. They do not affect the requirement to provide meaningful access to LEP
individuals through competent oral interpreters where oral language services
are needed and are reasonable. For example, correctional facilities should,
where appropriate, ensure that prison rules have been explained to LEP
inmates, at orientation, for instance, prior to taking disciplinary action
against them. 



Cindi Bowman
Quality and Compliance Coordinator
Catawba County Health Department
828-695-5847


-Original Message-
From: Christiansen, John (SEA) [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 18, 2003 5:43 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: NPP in Other Languages


Folks -

The plain language requirement for the NPP incorporates regulatory
requirements that include translation into other languages if they are a
material element of the population you serve. I did the research well over a
year ago so don't recall the citations, and don't have time to dig it up
just now, but I believe it was available via an OCR webpage. There are
criteria for determining what languages you need to include, and this would
apply to any CE, not just an employer plan.

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 insecure. Unencrypted e-mail may be
accessible to unauthorized viewers, content may be modified or corrupted,
and headers or signatures may incorrectly identify the sender. If you wish
to confirm this message or the identity of the sender, please contact me
using a communications channel other than a reply to this e-mail. Secure
electronic messaging is available and recommended for confidential or
sensitive communications.


-Original Message-
From: David Ermer [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 18, 2003 1:53 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: NPP in Other Languages


It strikes me as an attorney who represents ERISA governed health plans
that the NPP can be considered a material modification to the health
plan under the U.S. Labor Department's (DOL) rules. DOL, in contrast to
HHS, has very specific rules on distributing a summary plan description
or a summary of material modifications to a plan participant, i.e., hand
delivery, first class mail (second or third class only if return and
forwarding postage is guaranteed and address correction is requested),
or electronic delivery under certain circumstances and on when you need
to translate such plan documents into another language. If your covered
entity is governed by ERISA, I suggest that you apply these rules. If
you covered entity is not governed by ERISA, you still may find the
guidance helpful. I have quoted the foreign language and mailing
guidance below. Best regards, Dave Ermer

29 C.F.R. §2520.102-2 Style and Format of SPD:

(c) Foreign languages. In the case of either--
(1) A plan that covers fewer than 100 participants at the beginning

of a plan year, and in which 25 percent or more of all plan
participants 
are literate only in the same non-English language, or
(2) A plan which covers 100 or more participants at the beginning
of 
the plan year, and in which the lesser of (i) 500 or more participants,

or (ii) 10% or more of all plan participants are literate only in the 
same non-English language, so that a summary plan description in
English 
would fail to inform these participants adequately of their rights and

obligations under the plan, the plan administrator for such plan shall

provide these participants with an English-language summary plan 
description which prominently displays a notice, in the non-English 
language common to these participants, offering them assistance. The 
assistance provided need not involve written materials, but shall be 
given in the non-English

RE: NPP in Other Languages

2003-03-18 Thread Charles H. Thulin
John,

I don't agree that the plain language requirement of the privacy
regulations requires translation of the NPP into other languages.

In its discussion of the plain language requirement in the preamble to
the final privacy regulations DHHS notes that Title VI of the Civil
Rights Act -- a separate statute -- generally requires entities that
receive Federal financial assistance to provide material ordinarily
distributed to the public in the primary languages of persons with
limited English proficiency in the recipients' service areas, 65
Fed.Reg. 82461, 82549 (December 28, 2000),  thereby creating an
obligation in some cases -- for entities that are subject to Title VI --
to provide the HIPAA notice in non-English languages.  

Employer group health plans, for example, aren't subject to Title VI
(they don't receive Federal funds), and thus aren't required by Title VI
to provided notices in non-English languages.  DHHS suggests in the
preamble that the Title VI standards provide helpful guidance [to
covered entities that are not subject to Title IV] for effectively
communicating the content of their notices to non-English speaking
populations. 65 Fed.Reg. 82461, 82549 (December 28, 2000). That's no
mandate for employer group health plans (or any other covered entity
that's not subject to Title VI) to translate NPPs into non-English
languages.  

I think the OCR advice you refer to may be its Policy Guidance on the
Prohibition Against National Origin Discrimination as it Affects Persons
with Limited English Proficiency, 65 Fed. Reg. 52762, 53768 (August 30,
2000),
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2000_register;
docid=00-22140-filed, which creates a compliance safe harbor when an
entity covered by Title VI translates vital documents for groups of
limited-English proficiency individuals who are at least 5% of the
population of eligible individuals to be served.

Regarding Mr. Ermer's comment concerning SPD's, the regulation he cites
does not require translat[ion of] such plan documents into another
language.  It merely requires that English-language summary plan
descriptions in certain instances provide a notice in a non-English
language that assistance available from the plan administrator.  See
also Diaz v. United Agric. Employee Welfare Benefit Plan  Trust, 50
F.3d 1478, 1485 (9th Cir. 1995)(in no instance has the Secretary [of
Labor], after having given full consideration to the problems of
workforces that are not English-language-literate, imposed any
requirement that the operative document itself - either any summary plan
description . . . or any summary annual report . . . or any denial of
benefits such as those involved in this case . . .  - must be furnished
to employees in their native tongues.) There is no analogy to ERISA
that supports translation of the NPP into non-English lanaguages.

Charles H. Thulin
Ekman, Bohrer  Thulin, P.S.
220 West Mercer Street, Suite 400
Seattle, WA 98119
(206) 282-8221


-Original Message-
From: Christiansen, John (SEA) [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 18, 2003 2:43 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: NPP in Other Languages


Folks -

The plain language requirement for the NPP incorporates regulatory
requirements that include translation into other languages if they are a
material element of the population you serve. I did the research well
over a
year ago so don't recall the citations, and don't have time to dig it up
just now, but I believe it was available via an OCR webpage. There are
criteria for determining what languages you need to include, and this
would
apply to any CE, not just an employer plan.

John R. Christiansen
Preston | Gates | Ellis LLP
925 Fourth Avenue, Suite 2900
Seattle, Washington 98104
*Direct: 206.370.8118 *Cell: 206.683.9125
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-Original Message-
From: David Ermer [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 18, 2003 1:53 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: NPP in Other Languages


It strikes me as an attorney who represents ERISA governed health plans
that the NPP can be considered a material modification to the health
plan under the U.S. Labor Department's (DOL) rules. DOL, in contrast to
HHS, has very specific rules on distributing a summary plan description
or a summary of material modifications to a plan participant, i.e., hand
delivery, first class mail (second or third class only if return and
forwarding postage is guaranteed and address correction is requested

RE: NPP in Other Languages

2003-03-17 Thread Halfhill, Annette
We are currently having it interpreted into Russian, Somali and Spanish.

-Original Message-
From: Kathy Findley [mailto:[EMAIL PROTECTED]
Sent: Monday, March 17, 2003 2:08 PM
To: WEDI SNIP Privacy Workgroup List
Subject: NPP in Other Languages


Hello All!
I don't belive it's required according to the regulations, however, what is
everyone doing about having a version of the NPP in Spanish or other
languages?
Kf

Kathy Findley
Coordinator - Information Services and HIPAA
St. Joseph's Hospital Health Center
Phone - (315) 448-6111
Beeper - (315) 467-4180
Text Page - [EMAIL PROTECTED]
 

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RE: NPP in Other Languages

2003-03-17 Thread Sherry Neuman
Title: Message



In the compliance tool I have developed, I am 
offering not just the Notice in Spanish but the other important "patient" 
documents as well--the Authorization, Requests for Restrictions/Confidential 
Communications/Access/Amendment forms and the letters to patients denying 
access/amendment, as well as the complaint form.If the practice needs 
languages other than Spanish, I am leaving it up to them to get 
translations.I hope this helps.






Regards,
Sherry L. Neuman, 
PharmD

Compliance Solutions 
for Healthcare
Direct: 
209-744-0447
Mobile: 
916-747-0999
[EMAIL PROTECTED]

HIPAA Privacy Deadline is April 14, 2003
-Original 
Message-From: Kathy Findley [mailto:[EMAIL PROTECTED]]Sent: 
Monday, March 17, 2003 11:08 AMTo: WEDI SNIP Privacy Workgroup 
ListSubject: NPP in Other LanguagesHello All!I don't belive 
it's required according to the regulations, however, what is everyone doing 
about having a version of the NPP in Spanish or other languages? KfKathy 
FindleyCoordinator - Information Services and HIPAASt. Joseph's Hospital 
Health CenterPhone - (315) 448-6111Beeper - (315) 467-4180Text Page 
- [EMAIL PROTECTED]---The WEDI SNIP listserv to which you 
are subscribed is not moderated. The discussions on this listserv therefore 
represent the views of the individual participants, and do not necessarily 
represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to 
receive an official opinion, post your question to the WEDI SNIP Issues Database 
at http://snip.wedi.org/tracking/. 
These listservs should not be used for commercial marketing purposes or 
discussion of specific vendor products and services. They also are not 
intended to be used as a forum for personal disagreements or unprofessional 
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