Dan,
I had overlooked Leslie's mention of requiring authorization after it hits Medical Records. 
 
I agree with you that authorization is not necessary for sending medical info for Treatment purposes to another Physician.  I would think that the older the information, the more questions I would ask before releasing the information (just to be sure that the inquirier is really involved in the patient's Treatment).
 
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 -----
From: Dan Kelsey
Sent: Wednesday, March 26, 2003 08:30 AM
Subject: RE: section 164.514(d)(3)(iii)(B)

Leslie - I agree with your approach.  However, let me play devil's advocate on the last part of your message - Suppose I am a cardiologist, and am seeing a new patient in my office.  In talking to the patient I discover the patient was recently seen at your hospital - I call over to the hospital and ask for a copy of the EKG.  I need this information for treatment purposes - however, I was not involved in the patient's recent hospitalization. 

Based on your approach, I will need to get an authorization from the patient, fax it over to HIM at the hospital and then get the EKG.  I fully understand your reasoning.  But this is a covered entity requesting information for treatment.  The commentary also states that information can be released to individuals to the extent they are involved in the care of the patient.  Personally, I do not think the authorization is necessary.

My concern is that the approach you outlined could potentially delay the delivery of care to patients.  What if the roles were reversed?  What if I am a physician and do not have staff privileges at your hospital and am not part of an OHCA?  A patient of mine is hospitalized at your facility, and the hospital calls my office asking about medical history, etc.  - I then say, sorry you will have to get an authorization from the patient and fax it over to get the information - It certainly will not make the busy RN or staff physician very happy.

Like I said, I am not disagreeing with your approach, just playing devil's advocate.

Dan Kelsey
Practice Advisor
Indiana State Medical Association

-----Original Message-----
From: Harpe, Leslie [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 25, 2003 3:15 PM
To: WEDI SNIP Privacy Workgroup List
Subject: section 164.514(d)(3)(iii)(B)


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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