As a
Business Associate collection agency, we have not had any Covered Entity clients
request to track our disclosures themselves. The wording they have used
in our contracts instructs us to forward disclosure information if
they notify us of an accounting request. What we are doing is recording
our relevant disclosures on our information system, and upon request we will
forward them to the client when an accounting is requested for a certain
patient. For a BA like a collection or billing agency, I would imagine
that these types of requests will be fairly common, since we hold a lot of the
patient's information. I believe this is the most straightforward way to
go, but a Covered Entity should make sure the BA knows what types of disclosures
to record, and that might be a daunting task with some BAs.
Thanks,
Jason
Brege
Clinton A. Harkins, P.C.
--------Original Message-----I am curious how covered entities are tracking accountings of disclosures by business associates that they then have to provide to the patient. In some ways, this seems like a daunting task but then again, I am not sure how often it will come up... I would appreciate your thoughts.
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 11, 2003 6:43 AM
To: WEDI SNIP Privacy Workgroup List
Subject: Tracking Disclosures by Business Associates
Jill Rubin, Esq.
(617)388-2404
[EMAIL PROTECTED] ---
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