The name and the credit card number are not PHI under HIPAA. It does not become PHI until some health information is added. If the information contains CPT codes, for example, then you would either need to include that information in the Notice of Privacy Practices or obtain an authorization at the time of swiping the card.
One of the questions we had to answer was if the collection agency we used to collect bad debt was a busness associate. We found that all they needed was the guarantor's contact information and an amount. No health information was needed for them to perform their task. Therefore they were not a business associate.
Roy G. Clay III
Interim Compliance Officer
Louisiana State University Health Sciences Center
New Orleans Campus
Phone: (504) 568-4367
Fax: (504) 568-6378
Email: [EMAIL PROTECTED]
-----Original Message-----
From: Christine Hudnall [mailto:[EMAIL PROTECTED]]
Sent: Friday, February 28, 2003 2:36 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Another thread on Security/Privacy question
I'm sending this out again, if someone could please help us. Thanks.
Christine
What about the card swipes that we use when a patient makes a
payment on their account using their credit card. Yes, we only
swipe the card and put in the last four digits of the number, but
the patient name (or whoever owns the card) prints out on the
receipt.
Is that considered PHI, even though we are not sending them the
name, but they print it from their records?
If so, do we need to have an agreement with the company that we use
the card swipe from?
And as for eligibility, i.e., Medicaid. We use ROVR, which is
through Consultec (if I remember correctly). Is an agreement needed
with them?
And how would I check for security for their program? Is that
something they would need to do and put in writing?
Sorry for all the questions, just, my co-worker and I are trying to
go down list of all possibilities that we need to check on.
Thanks,
Christine
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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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