I had someone ask me a question the other day that I hadn't heard before and it got me curious as to whether other people had confronted this issue and what their outcome was.
This person said they were told by someone that HIPAA requires that providers keep patient's medical records separate from their financial records. Most providers I deal with have the bulk of their financial data in whatever software package they are using to file their claims. The clinical notes are kept in paper charts, however quite often they keep a copy of the patient's insurance card in the chart and that specifically was the "financial record" that they were concerned about being in the same place as the "medical record". My immediate reaction was that there is no specific requirement to do this in the Privacy rule but I then started to think about what could possibly be the basis of such a statement? The only thing I could come up with was the requirements under the minimum necessary standard to identify who need access to what types of PHI, and to then make reasonable efforts to limit access accordingly. Upon further thought I can see how someone might take the position that a persons's insurance card or other insurance information should not be necessary for the clinical staff to treat the patient. Similarly, the front office and billing personnel do not need any more clinical data than what appears on the superbill so they should not have access to the entire chart. Perhaps this is where the conclusion that insurance information cannot be kept in patient charts comes from? Has anyone else heard this opinion or possibly come to the same conclusion on their own? In small office settings, quite often I have clients that are taking the position that everyone in the office needs access to everything because of the degree of job sharing and multi-tasking that goes on. However (playing devil's advocate for a moment) just because you might need access to a piece of PHI when you are asked to cover a job for a sick co-worker, does that justify you always having access to that PHI including when you are performing tasks that do not require that piece of PHI? I have not encountered one physician's office that uses paper charts where the chart does not start out in the hands of the people at the check-in window. Do they really need access to the complete chart (medical history, docotor's notes, lab results, etc.) to check in a patient? The more I think about it the more I can understand how someone might arrive at this position but talk about an impediment to work flow! Do we now need one set of charts for financial data that is not in software systems (e.g. copies of insurance cards) and a separate set of charts for clinical data? Someone please show me a convincing out! Noel Chang Noel Chang Integral Practice Solutions -- Open WebMail Project (http://openwebmail.org) --- 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. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
