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Gregory,
Your client is wrong. Accounting for Every disclosure if
definately not required by the Privacy or Security regs. Most transactions
involving the Treatment of Patients and obtaining Payment are explicitly
excluded from the need to report them (in very great detail as to what is
excluded). Get out your reading glasses, because it is all detailed in the
Federal Register (small print, and lots of it!).
In our case, operating as a Billing Service, we have never in
our history encountered a situation that would result in a release of
information that would have to be reported.
The major categories of reporting would be releases related to
responding to Audits and Sopoenas.
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: Thursday, March 27, 2003 11:10
AM
Subject: NPP and Disclosure
I have a client that has written within their NPP that the
patient can
demand an audit of every (NOTE EVERY) disclosure of their PHI,
even if this
disclosure is related to patient care and billing.
It
is my understanding that this is not dictated as a requirement
within
Privacy, and only is briefly mentioned in Security as something that
must be
accomplished for disclosure outside of patient care or billing (for
example
governmental disclosure, or legal).
I need confirmation
because the particular client is stating that all of its
vendors now must
provide an audit trail of every action (print, copy, email)
according to
the regulations.
If I am wrong, then maybe this isn't
simplification?
Thanks in advance.
Greg Park
Product
Manager
DB Technology
Inc.
Office:
800-760-4096
x117
Cell:
484-919-0392
PA Office:
610-397-0288
-----Original Message-----
From: Bill Cushing
[mailto:[EMAIL PROTECTED]
Sent: Thursday, March 27, 2003 11:35
AM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: Patient Phone Calls
and NPP
Can anyone please confirm the HHS/OCR phone number that
we
should be using for the NPP?
Thanks, Bill
At 09:25 AM
3/27/2003 -0600, KERBER, JEFF wrote:
>Vicki,
>
>This is an
ongoing issue with HHS/OCR -- ask a question twice, get two
>different
answers from different people.
>
>Jeff
>
>Jeff
Kerber
>Director, HIPAA Compliance
>Texoma Healthcare
System
>903-416-5520
>
>
>-----Original
Message-----
>From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]
>Sent: Wednesday, March 26, 2003 3:55
PM
>To: WEDI SNIP Privacy Workgroup List
>Subject: Patient Phone
Calls and NPP
>
>
>After 4/14, when a patient calls for a
prescription refill, or to ask a
>medical question, are we obligated to
then mail them a copy of the NPP and
>ask them to send us a signed
acknowledgement? A question like this was
asked
>regarding
prescriptions at the Atlanta OCR conference in February and the
>answer
that day was no, the next visit would be the occasion to give the
>NPP.
Today, on the OCR conference call, a similar question was asked
and
the
>answer was that the NPP needed to be mailed. Can anyone
direct me to a
>reference or guidance on this?
>
>Vicki
Saunders
>Compliance Manager/Privacy
Officer
>[EMAIL PROTECTED]
>
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