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 --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org