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Leslie,
To build on what Leah said, I think that what you have in your
NPP is OK, but possibly goes into unnecessary detail (Don't kill any more
trees!).
The opinions expressed here are my own and not necessarily the opinion of
LCMH.
Douglas M. Webb Computer System Engineer Little Company of Mary
Hospital & Health Care Centers [EMAIL PROTECTED]
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----- Original Message -----
Sent: Tuesday, March 25, 2003 03:03
PM
Subject: Re: section
164.514(d)(3)(iii)(B)
Leslie,
In my opinion, while it would be good to apply
some minimum necessary
principals, I don't think you are required to do so
in this situation.
Because these are providers (covered or not)
using, disclosing, and
requesting the PHI for treatment.
Under 164.502(b)(2) - min. necessary doesn't apply to disclosures to
or
requests by a health care provider for treatment.
And under
164.506(c)(1) - covered entities can use/disclose PHI for its
own treatment
activities and (2) for treatment activities of (another)
health care
provider.
Regards, lhc
Leah Hole-Curry, JD
FOX Systems,
Inc.
602.708.1045
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>>> "Harpe, Leslie" <[EMAIL PROTECTED]> 03/25/03
12:21 PM >>>
Your opinions on the following scenario:
A patient
is seen in the ER last night. Dr. A ordered labs. Dr.
B
calls
the lab for the results today. Lab only knows the ordering
doctor.
Based
on the fact that Dr. B knows labs were ordered and
according to section
164.514(d)(3)(iii)(B), we are going to release the lab
results without
an
authorization. We believe that this is
continuum of care and we are
releasing to another covered entity. (No
disclosure is required either.)
If
each department identifies who
can release the info, the minimum they
can
release for routine
disclosure and develop criteria for non-routine
disclosures, this should be
an acceptable practice. Page 82545 also
supports
this
interpretation. My notice also informs the patient that we will
do
this as continuum of care.
Once the chart is received by medical
records though, we will require an
authorization if the physician is not on
record.
I hope this is right, if not, we'd better start planting
more trees to
support the tremendous mounds of paperwork.
Thanks,
Leslie Harpe
Privacy Official
South Georgia Medical
Center
Valdosta, GA 31603-1727
[EMAIL PROTECTED]
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