RE: EMS and the NPP

[Beth . Kranda]

Chris' comment is not correct. The referenced standards for consents were removed (except to say you optionally may have one) in the final regulation as revised on 8-14.  Please make sure you are using the current rule and review the implementation specification for delivery of the notice.  164.520(c)  A notice must be provided upon request.  But this is in addition to not instead of the other instances when it must be provided and that includes at the time of first treatment unless it is and emergency and then as soon as practicable.   A provider would not be in compliance if they were to provide their notice only upon request, whether it is referenced in a consent form or not. On this topic I would advise you all to read the regulation, it is pretty clear on the delivery of the notice. Thanks, Beth Kranda -----Original Message----- From: Chris Brancato [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 23, 2003 12:31 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: EMS and the NPP The consent can refer to the NPP, and the NPP can be provided upon request.   Christopher P. Brancato Compliance Officer Manager, Development/Product Management Suite 3 503 Faulconer Drive Charlottesville, VA 22903-4978   434-817-9000 800-800-4021 (toll free) 434-817-9006 (FAX) [EMAIL PROTECTED] www.healthdataservices.com   The information contained in this message may be privileged and/or confidential and protected from disclosure. If the reader of this message is not the intended recipient or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited.  If you have received this communication in error, please notify the sender immediately and delete all copies of the material.   -----Original Message----- From: Ribelin, Donald [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 23, 2003 11:55 AM To: WEDI SNIP Privacy Workgroup List Subject: RE: EMS and the NPP   Spencer, this is not how I read this provision.  I believe you must provide the entire NPP, not just part of it.  IMHO, the layer is simply a bulleted cover sheet that is meant to assist the patient in better understanding their rights.   Donald L. Ribelin HIPAA Project Manager Firsthealth of the Carolinas (910) 215-2668 [EMAIL PROTECTED]   -----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]     --- 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. 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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. 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 --- 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. 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 --- The WEDI SNIP listserv to which you are subscribed is not moderated. 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