We received a legal opinion regarding Organized Health Care Arrangements
(OHCA's) that I want some feedback on:
We have doctors/psychiatrists/psychologists that are independent
contractors.  They come on site, do physicals, assessments, etc.... We have
considered them to be a part of our workforce as we pay them for the
services they provide and they function much like any other staff member.
The legal opinion we received is that they are OHCA's and as such are to be
disclosed in the privacy practice notice.
The attorney thinks this is necessary even though they are part of our
"workforce" and have been trained as a part of our workforce.  

Any thoughts?  This is out of the blue for me.  We had determined that our
organization was NOT an OHCA (we have 7 facilities around the country but
all are owned or managed by the corporate entity) and have never heard
before that independent contractors are OHCA's...  


Janelle J. Wesloh
RMIS System Coordinator
Quality Standards 
Hazelden Foundation



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