--- You are currently subscribed to wedi-privacy as: [email protected] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- I would like to especially direct this email to those plans that have specific reporting needs for OB (maternity) care.
Our plan has been using the deleted code 59420 for providers to bill antepartum visits and for reporting to Medicaid. Per HIPAA we cannot use deleted or homegrown codes. Our providers would like for us to switch to global billing. However, global billing does not give us the dates that are needed for Medicaid and other reporting needs. If we go to Global billing we will need to do 100% medical record review. How are other plans handling this? Thanks, Bert Bradley -Original Message----- From: Patricia Hamby [mailto:PHamby@;xantushealthplan.com] Sent: Wednesday, October 23, 2002 9:49 AM To: WEDI SNIP Privacy Workgroup List Subject: RE: HIPAA-related privacy question (I think) --- You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- This provider should realize that, as of October of 2003 Medicare will accept claims electronically only (unless stringent conditions apply). Patricia Hamby Project Manager, HIPAA Compliance XANTUS Health Plan of Tennessee, Inc. 3401 West End Ave., Suite 470 Nashville, TN 37203 (615) 463-1612, Office (615) 279-1301, Facsimile -----Original Message----- From: Christiansen, John (SEA) [mailto:JohnC@;prestongates.com] Sent: Tuesday, October 22, 2002 2:51 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: HIPAA-related privacy question (I think) --- You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- Jan has identified a problem which has come up for me, too, in a somewhat different variant: <<SNIP> The setting: 1. The provider elects not to do HIPAA transactions and thus is a non-covered entity. <SNIP> Issue: Because the provider is a non-covered entity (NCE), and, hence, is not subject to the Privacy Rule, are payers going to include in their NCE provider-payer contracts some kind of stipulation that the NCE provider protect PHI? (I don't think you can use a business associate contact to do this: The provider cannot be a business associate because they are not performing any of the payer's covered entity functions, yes?.) <SNIP>> #1 I think it is correct that the provider is not a business associate in this scenario. #2 Sec. .530(c) of the privacy rule requires CEs to implement "safeguards" to protect PHI. BACs are required under secs. .502(e)/.504e) as "satisfactory assurance" that the BA "will appropriately safeguard" PHI. So, shouldn't a CE (payer in Jan's scenario) get something equivalent to a BAC for any use/disclosure of PHI by a NCE (provider in Jan's scenario), if the payer is responsible for the protection of the PHI which is in the NCE's control, even if they are not technically BAs? Where else could this come up? E.g. plan NCQA accreditation audits of provider records by third party auditors - they aren't BAs of the providers, but can the providers afford to simply count on the auditors' ethics and their contracts with other parties? I wouldn't recommend it, and when it came up for a client I didn't - we required a separate agreement between the auditors and my client. This same issue is also currently coming up in an occupational medicine context, so this is clearly a "live one." From: John R. Christiansen Preston | Gates | Ellis LLP 701 Fifth Avenue, Seattle, Washington 98104 *Direct: 206.613.7118 - *Cell: 206.799.9388 * [EMAIL PROTECTED] Reader Beware: Internet e-mail is inherently insecure. Unencrypted e-mail may be accessible to unauthorized viewers, e-mail content may have been modified or corrupted, and e-mail headers or signatures may incorrectly identify the sender. If you wish to confirm the contents of this message or identity of the sender, or wish to arrange for more secure communication please contact me using a communications channel other than a "reply" to this e-mail. Thank you. --- 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 communication at any time. --- 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 communication at any time. --- 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 communication at any time.
