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Gregory
There is a difference between compound authorizations (one
authorization for several things, which is prohibited) and several
authorizations on the same piece of paper (which is OK, just so long as each one
has an indication that it was individually considered). To make it clear
that each authorization is separate, you could enclose each in a
box.
Previous discusson on this listserve asked the question if the
piece of paper could be signed once, and then each other area initialed, and the
conclusion seemed to be 'Yes' (to my understanding, anyhow). It would be a
good idea to allow for Patient and Subscriber signatures and/or initials
separately.
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: Friday, March 28, 2003 08:35
AM
Subject: RE: Multiagency
authorizations
I know a
lot of hospitals that are disregarding this point. More often than not I
understand that many of my clients have decided to piggy-back the NPP receipt
verification along with their existing Treatment Authorization forms, but I
suppose this is a matter of how you look at it. The treatment
authorization form may not have information regarding your notice of privacy,
but can your notice of privacy include a consent for treatment?
I suppose
this argument could be made?
Again, the
spirit of these regulations is to simplify healthcare, and protect patient
rights.
Greg Park
Product Manager
DB
Technology
Inc.
Office:
800-760-4096
x117
Cell:
484-919-0392
PA Office: 610-397-0288
www.dbtech.com
Several people on our HIPAA implementation team are
hoping others input might help in resolving our question
about HIPAA's instructions to avoid compound authorizations and how
that relate to the use of multi-agency authorization
forms.
The final HIPAA Privacy regulations - 164.508 (b)(3)
- prohibit the use of compound authorizations (i.e., combining with any
other document an authorization for use or disclosure of phi...except for
limited and specific exceptions).
We are a county-operated yet multi-jurisdictional
behavioral health organization that plans, contracts, and directly
provides treatment & prevention services. We are one
of several covered health care components of our County government's
hybrid entity. Much of the clinical work we do is as part
of collaborative teams with other organizations (i.e., court
staff, county social service staff, coordinating offices that serve as
fundors, and other community groups, agencies & service providers).
In
the past, the local human service organizations that staffed such
efforts agreed to use a multi-agency "Universal" authorization form.
This form includes checkboxes for the various organizations involved, and
then all of the other listed elements of a valid
authorization. The clinical staff point out the obvious
benefit that staff and the client need only sign one
form.
The other point of view is that proffered by our MIS vendor and
endorsed by several groups similar to ours in the state is the single
purpose release forms, which allow for only one-on-one exchanges of
information between entities. This option assuries that the system
records the limits of each release individually. Primarily the
technical staff consider the single agent/purpose release form to conform to
the spirit of the regulations...but clinicians believe that they will create
an overwhelming paperwork burden on staff & clients.
I've found the language of this section confusing, and would be
interested in knowing how others have interpreted this section and resolved
the issue of handling releases of information when working with clients
involved with numerous organizations.
Thanks in advance for any insights you can offer.
Laura
Schmitt, Business Analyst
Fairfax-Falls Church Community Services
Board
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