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One thing to remember is that CMS said its enforcement will be complaint
driven. So who of the 550,000 entitites who filed for the extension or who
among the unknown number of entities that did not file for an extension
because they are in compliance will complain.
Then, how will anyone who complain know if the organization they are
complaining about did not file for an extension?  And where will CMS get the
resources to hunt down the reprobates?
One of the only reasons to go after someone in this area is to embarass the
non-extending offender in the marketplace.
So the bottom line seems to be that if you didn't file for an extension, you
should start planning to comply although it is unlikely that very many
organizations will be have to provide a corrective action plan -- whatever
that may be. CMS, of course, is working on guidance in this area. But does
the industry want to spend a lot of time on this?
Regards,
Dennis Melamed
Editor
Health Information Privacy Alert

-----Original Message-----
From: Zalewski Andrea [mailto:Andrea.ZALEWSKI@;HCAhealthcare.com]
Sent: Monday, October 21, 2002 4:00 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: Transaction Extension Plan


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If you go to the Q&A site, it says that they are now in violation and need
to have a "Corrective Action Plan" in case they are audited.  Really,
documenting the plan is all they can do.  CMS took the site down 10/16.

Andrea R. Zalewski
Director of Quality Assurance and HIPAA
HCA Physician Services [EMAIL PROTECTED]
<mailto:andrea.zalewski@;hcahealthcare.com>

Three Maryland Farms, Suite 250
Brentwood, TN 37027
Office - 615-373-7434; 800-661-3365, ext. 7434
Cell - 615-456-1809
Fax - 877-288-1348

"Quality is never an accident; it is the result of high intention, sincere
effort, intelligent direction and skillful execution; it represents the wise
choice of many alternatives." -- Willa A. Foster

**Confidentiality Notice**



The documents accompanying this transmission contain confidential privileged
information.  The information is the property of the sender and intended
only for use by the individual or entity named above.  The recipient of this
information is prohibited from disclosing the contents of the information to
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-----Original Message-----
From: Nancy Jones [mailto:jonesn@;nacmem.org]
Sent: Monday, October 21, 2002 2:05 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Transaction Extension Plan


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