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"164.510 - Uses and disclusres requiring an opportunity
for the indiviudal to agree or to object " . The citation even says that
"the entity may orally inform the individual of and obtain
the individual's oral agreement or objection to a use or disclusire permitted by
this section". In the Preamble it states three conditions under which a
patient can be listed in the directory, 1. the NPP is given; 2. they give the
patient a meaningful opportunity to opt out of the directory or to
restrict all or some of the uses and disclosures in the directory; 3. pt.
does not object to being in the directory. (this is on page 82521of the
Dec 28, 2000 Fed Reg) Seems to me (IMHO) that this is part of the
dialog registration will have to have with the patient, not just the patient
reading the NPP. Thanks Cindy
Cindy Rupe, RHIA, CPHQ
HIPAA Coord/Consultant
406-247-7161
[EMAIL PROTECTED]
HIPAA Ready, HIPAA
Compliant, and HIPAA Aware
In
reading the other responses to this, I'm shocked admissions isn't already
doing this in most facilities. In the many discussions I have had with other
hospitals the question on this has never been do we have to even tell them of
the option. The question has always been how will this change what we ask (ie,
clergy). Most hospitals do this as part of JCAHO standards R.1.3.1,
R.1.3.2, R.1.3.1, R.1.3.6.1 and R.1.3.6.1.1
That
said... while you aren't required to tell them when they are admitted.
Shouldn't you? Think about it. How many patients are going to sit and read
your 3-8 page NPP and let you know they want to opt-out of the directory? This
is a question of doing the right thing.
For some reason I have been under the
assumption that when a patient registers we, an acute care hospital, need to
explain the right to opt-out of the facility directory. Is this something we
need to explain verbally or is the fact that explanation in the NPP is
sufficient? I really appreciate any feedback
Cindy ---
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