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Judith,
Yes, such disclosures are also on the short list of what needs
to be accounted for. We try to keep all such as infrequent as
possible. So far, if they were logged in the past, the list would still be
on its first page.
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 02:03
PM
Subject: RE: NPP and Disclosure
Doug,
What about releasing the incorrect information? Faxing the wrong
file? These are all disclosures that need to be accounted for,
right?
Judith Bentz-Miller
Privacy Officer
Arnett Clinic
765-448-8843
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]
"This electronic message may contain information that is confidential
and/or legally privileged. It is intended only for the use of the
individual(s) and entity(s) named as recipients in the message. If you
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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]
>
>Confidentiality
Notice: The information contained in this e-mail
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>
>
>---
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>"This
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>---
>The WEDI SNIP listserv to which you
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listservs should not be used for
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