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Actually we do have a law protecting your private
banking information, it is called the The
Gramm-Leach-Bliley Act (GLBA) - Enacted in
1999, GLBA requires financial institutions to protect nonpublic personal
information (NPI) for distribution beyond the financial institutions network.
I agree Sherry. Buttttt... while bank
transactions are usual private, we don't have a law protecting PBI, and we're
not likely to find bank patrons photos on the walls no matter how satisfied
that are with the service. And of course one could draw the same
inference just seeing the celebrity enter the medical office. But in
these cases the image of the celebrity and the potential connection to the
medical office are there for all visitors to view 24x7.
I think this is only a question for the group because of the concern we
have seen over lists of patients (and assumed PHI) being visible on login
sheets, whiteboards, file folder tabs, envelopes, computer screens, etc.
I'm sure the celebs would have no problem giving the CE approval to leave the
photo up if they are still patients. But again, many off these photos
have been up for 5, 10 or more years and it would be unlikely the doctor still
sees them all or could even track them down. And some they may even
prefer to take down. I think the only real problem is going to be the
photos with inscriptions thanking the provider for medical care.
Another tactic might be to ADD more photos of totally unrelated celebs to
the wall. I have a client that is a world-class amateur photographer
with walls covered by dozens of auto road racing pix along with photos of
drivers thanking him for the dramatic shots ... not a patient among
them. This is his hobby and he should not need to worry.
FWIW.
--Fred Dietrich
1-877-4-CHARTS
---------------------------
Sherry Neuman wrote:
Fred, I would go the other way and say a celebrity’s picture on the
clinic wall is not PHI. By analogy, if a person is seen going into the bank,
are they presumed to have money? Maybe, maybe not. Perhaps they have NO
money and are going in for a loan. I’m not sure you can draw any conclusion
from a picture on a wall or a person entering a bank or any other isolated
piece of information.
On the
other hand, there probably aren’t that many pictures on any one wall and the
health care provider could get an authorization to leave it hanging from the
celeb; problem solved!
Regards,
Sherry L. Neuman, PharmD
Compliance Solutions for Healthcare
Phone/Fax: 209-744-0447
Mobile: 916-747-0999
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