Setting HIPAA aside (only for a split second), in my view this approach will further
annoy patients/clients who call a doctor's office to speak to a person, not to hear an
endless usually irrelevant and insulting electronic broadcast - like, "If this is a
medical emergency, hang up and call 911." and, "Please listen carefully as our menu
has changed."
Back to HIPAA, though, I don't think that announcing that the NPP is available on the
web site (or in your waiting room) logically leads to the conclusion that the NPP is
thereby acknowledged. It assumes that the caller was able to retain the instructions,
followed them, and read the NPP.
Rebecca
>>> "Oriol, Albert" <[EMAIL PROTECTED]> 03/28/03 11:24AM >>>
Here's a thought, you all tell me how liberal an interpretation this is. We're
required to provide the notice and document acknowledgement, right?
If we mail something, we can't be sure the patient has gotten it unless it's
registered mail (which would be unreasonably cost prohibitive).
So how about giving them the option of referring them to a website where the NoPP is
posted as part of the script of you call or getting it mailed?
You could set this up so that incoming calls get staged and must listen to
instructions on how to get the NoPP on your website while they're on-hold (and you
instruct them to let you know if they'd rather you mail the NoPP to them). You don't
answer until the message has been played, so you can assume if they don't tell you to
mail it, they'll get the notice from your web site if they want it. This would cut on
the amount of mailing.
Too liberal?
a.
Albert Oriol, CHE, CISSP
The Children's Hospital, Denver
(303) 861 6094
"Knowledge is the most democratic source of power"
-- Alvin Toffler
-----Original Message-----
From: Noel Chang [mailto:[EMAIL PROTECTED]
Sent: Thursday, March 27, 2003 9:53 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: Patient Phone Calls and NPP
Vicki,
In the preamble to the Modifications to the Final Rule that was published in
August of 2002 (Federal Register/ Vol. 67, No. 157) on page 53240 there is a
discussion about service that is delivered by phone. Here is where HHS has
suggested that for service delivered by phone, the NPP must be mailed to the
patient "no later than the day of that service delivery".
They clarify that if the initial phone contact is simply to schedule an
appointment, then the Notice does not have to be mailed but can be given to
the patient when they arrive for their appointment. Unfortunately, that is
the only scenario they specifically address so I would infer from that that
any other service conducted by phone (such as refilling a prescription) would
require you to mail the NPP to the patient that day.
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 16:54:53 -0500
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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