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“What’s up in the world of HIPAA and Fire Department/EMS? Are there any specific mandates aimed at public services? I am being asked a lot of questions because of my volunteerism and I’d like to be complete and correct with the latest interpretations beyond ‘what’s been considered confidential in the past is still confidential and protected’.”
Opinions offered so far are below but we would appreciate any comments or additional considerations. Thank you!
· If the EMS does any kind of electronic billing, they are a covered entity. · If a covered entity, then they have to be compliant. · Biggest, most obvious issue with Privacy for them is how to handle a Notice of Privacy Practices. Since many of those they are caring for are in no condition to receive and comprehend a NOPP, they will need to provide the NOPP at a later time when they have recovered. Most hospitals are not going to want to take on this responsibility for them, so my guess is that they will get into a mailing situation. And they’ll need to request the patient to sign an acknowledgement for the NOPP. · Reviewing a sample EMS/ambulance company NOPP for them to model would be helpful – perhaps ambulance companies would tell us what preparations they’ve made to be compliant. · The EMS folks may consider approaching a hospital about being a part of their OHCA. · One final thought, they should NEVER identify the patient by name over the radio. People and news media use scanners to monitor those frequencies. They should ONLY address their patient by age & gender for the sake of the ER folks to be prepared. And unless they have some local or state regulations that require it, they should not identify patients for the media, etc. n Consider situations when not identifying the patient by name might impede healthcare delivery – The receiving facility will not be able to pull/research past records of care. Consider adding some type of language stating when the patient’s name will be given to the policies.
Christine L. Stahlecker Principal Consultant
CTG HealthCare Solutions, Inc. 312 Plum Street, Suite 700 Cincinnati, OH 45202 Phone: (315) 461-9136, (315) 727-9493 (cell) VM: (800) 992-5350 x1510 Fax: (315) 461-0548 E-MAIL: [EMAIL PROTECTED] WEB: www.ctghs.com
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