Daryl, I don't think the Business Associate provisions of HIPAA have any bearing on your situation.
You probably want to consider forming an Organized Health Care Arrangement (OHCA) with the hospitals you work with. Being in an OHCA allows the hospital to take care of providing a Notice of Privacy Practices to the patient and you (as a participating member of the OHCA) no longer have to provide your own Notice. Being in an OHCA also allows you to more freely exchange information between your office and the hospital for operational purposes. I refer you to the following sections of the Rule for more reading on OHCA's: Section 164.501 - Definition of an OHCA Section 164.506(c)(5) - Disclosure of PHI for operations between members of an OHCA Section 164.520(d) - Joint notice by separate covered entities Hope that helps, Noel Chang Integral Practice Solutions -- Open WebMail Project (http://openwebmail.org) ---------- Original Message ----------- From: [EMAIL PROTECTED] To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]> Sent: Wed, 26 Mar 2003 09:13:24 EST Subject: Contract Between Anesthesia Group and Hospital > We are an Anesthesia Group Practice that has contracts with > facilities > (hospitals) that we provide anesthesia services for. Do we need to > have a separate Privacy Notice Issued and Acknowledgment signed or > can we just have a "Business Associates" by adding this language to > our existing contract? > > Surely this is something that is coming up a lot with outside Labs, > Radiology, Physical Therapists that are not facility employees and > that do their own billing based on information that they receive > from the facility. > > Thank in advance for any information or experience with this matter. > > > > Daryl Ewing, CPC > RPK Anesthesia, P.A. > [EMAIL PROTECTED] > > --- > 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 ------- End of Original Message ------- --- 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
