RE: EMS and the NPP

[Beth . Kranda]

I disagree.  The concept of the layered notice is not an "instead of" standard.

It is not mentioned in the regulation at all, and when it is discussed in the preamble they clearly say to provide it AND the full NPP.

 

from p. 53242:  (1) A short notice that briefly describes, for example, the entity's principal uses and disclosures of an individual's health information, as well as the individual's rights with respect to that information; and (2) a longer notice, layered beneath the short notice, that contains all the elements required by the Rule.

from p. 53243:  For example, a covered entity may satisfy the notice provisions by providing the individual with both a short notice that briefly summarizes the individual's rights, as well as other information; and a longer notice, layered beneath the short notice, that contains all the elements required by the Privacy Rule.

The concept is more like an Executive Summary that is provided at the beginning of the full report.  You must provide them both at the same time.  There is no provision that you make your NPP available only upon request.

Beth Kranda

 

-----Original Message-----
From: Spencer Hall [mailto:[EMAIL PROTECTED]]
Sent: Thursday, January 23, 2003 10:33 AM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: EMS and the NPP

The recent guidance allows for a "layered" NPP - you can provide your customers with a shot form and then provide the long form if it is requested. 

 

 

Spencer D. Hall

Health Information Security Officer

St. Vincent's

(904) 308-7029

[EMAIL PROTECTED]

>>> "Ribelin, Donald" <[EMAIL PROTECTED]> 01/23/03 07:56AM >>>

Chris, thanks for the feedback. Biggest problem, our NPP is five pages (front and back) long.  Attaching it becomes an issue secondary to its bulk.  Good point about 911 calls.  We are less worried about them.   

 

Donald L. Ribelin

HIPAA Project Manager

Firsthealth of the Carolinas

(910) 215-2668

[EMAIL PROTECTED]

 

-----Original Message-----
From: Chris Brancato [mailto:[EMAIL PROTECTED]]
Sent: Wednesday, January 22, 2003 10:20 AM
To: Ribelin, Donald; WEDI SNIP Privacy Workgroup List
Subject: RE: EMS and the NPP

 

Don,

I consult with some of the nations largest Fire/EMS departments for HIPAA.

I advise several different ways. Non-transports require a treat and release signature from a patient.

A copy of NPP can be printed on the back or separately, but they should make a "reasonable attempt" to provide the NPP. What you don't say is how they are activated. If they are activated via 911, this is an emergency response, not requiring an NPP as the call is emergency, not routine, in nature.

 

I also advise departments that do the billing to include the NPP in the billing statement, just like the Credit Card companies do.

 

Hope that helps.

 

Chris Brancato

 

-----Original Message-----
From: Ribelin, Donald [mailto:[EMAIL PROTECTED]]
Sent: Tuesday, January 21, 2003 8:03 AM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: EMS and the NPP

 

An interesting question from our EMS HIPAA rep yesterday:

 

When EMS treats and transports an accident victim to another hospital (one not part of our enterprise), should we give them a copy of our NPP?  One of the underlying issues centers on our management of EMS in several counties.   While most of the patients involved end up at FirstHealth facilities (where they would receive a copy of the NPP once their condition allowed), a significant minority are transported to other hospitals. On first look my response is that the receiving facility would be responsible for providing the patient with a copy of their NPP.  But is that the case?  I would like the group's comments, opinions and citations re: the whole ems issue.  I am also looking forward to OCR's clarifications on these issues.

 

 

Donald L. Ribelin

HIPAA Project Manager

Firsthealth of the Carolinas

(910) 215-2668

[EMAIL PROTECTED]

 

 

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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.

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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.

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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.

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