The way that I have interpreted the reg is the following:
 
The ER docs and Radiologists are by definition an OHCA with the hospital....or should I say they are an integrated care setting and therefore meet the definition -and therefore can CHOOSE to do a joint notice if they want to.....the notice will specify who is covered and where.  I don't think anything official needs to be done to declare yourselves an OHCA - each provider(CE) must agree to abide by the joint notice - which leaves you various avenues in which to accomplish this.
 
The guidance issued in December
----- Original Message -----
Sent: Tuesday, March 04, 2003 1:39 PM
Subject: Another OHCA question

I am helping our groups of hospital-based radiologists and emergency physicians comply with HIPAA.  My understanding has been that the hospital-based rad's and er doc's operate under the facility's notice of privacy practices, with or without an official OHCA document.  In other words, forming an OHCA is not necessary.  How are others approaching this?
 
Nancy Martin
Director of Compliance
OPS
 


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