As a side-bar: I've been thinking for some time about "disclosure accounting"... but more from the point of view of "What types of health information messaging might I, as the business owner, want to track in some sort of central communication log/repository?" While HIPAA does mandate certain types of disclosure auditing, I would suggest that developers step back and think about tracking a superset of communication events (bills to patients, claims, follow-ups, resubmits, rejections, etc. would be nice to track... basically "collection efforts"; product recalls/warnings; notices that additional treatment/visits are needed; appointment reminders, etc.) that support the business needs of the owner AND meet [this week's version] of the Privacy Rule.
Regards, Chris At 12:51 PM 8/27/2002 -0500, Lisa Cavitt/SIH wrote: >If it is TPO for our entity, we are covered and do not need to disclose, >but if it disclosing to another entity, it is not covered. > >For example, we currently provide an ambulance service a listing of the >patients that they have brought to one of our hospitals. The ambulance >service does not have the time to get billing and demographics information >on the front end and rely on us. We would need to account for that >disclosure, since the ambulance is not part of our healthcare system nor is >it providing a service on our behalf. > >Lisa R. Cavitt >Southern Illinois Healthcare > > > > > > "Lamb, > Tina" > > <[EMAIL PROTECTED]> To: 'Lisa > Cavitt/SIH' <[EMAIL PROTECTED]>, > [EMAIL PROTECTED] > > 08/27/02 11:11 > AM cc: > Subject: RE: Accounting > of Disclosures: > > > > > > >This would be very difficult to accomplish. > >Would this not fall under the TPO exception since this information is being >disclosed for billing purposes? (and there would also be a business >associate agreement among the covered entity and the billing service) > >Thanks! >Tina C. Lamb >HIPAA and Corporate Compliance Coordinator >St. Francis Hospital, Inc. >706/596-4411 x 5657 > > >-----Original Message----- >From: Lisa Cavitt/SIH [mailto:[EMAIL PROTECTED]] >Sent: Tuesday, August 27, 2002 11:01 AM >To: [EMAIL PROTECTED] >Subject: RE: Accounting of Disclosures: > > > >Another example is billing information made to other covered entities. In >the most recent final version, we do not have to receive authorization, but >I do not see an exception from the accounting for such disclosures. > >Lisa R. Cavitt >Southern Illinois Healthcare > > > > > > "Lamb, Tina" > > <[EMAIL PROTECTED]> To: >"'[EMAIL PROTECTED]'" <[EMAIL PROTECTED]>, > [EMAIL PROTECTED] > > 08/27/02 09:45 AM cc: "'Noel, Linda A.'" ><[EMAIL PROTECTED]> > Subject: RE: Accounting of >Disclosures: > > > > > > > >Examples of disclosures that have to be accounted for: >* Any disclosures made due to mandatory reporting, such as reporting >of communicable diseases >* Disclosures made to authorities, such as reporting of suspected >abuse or neglect, suspicious situations, locating suspects, crime on >premises, for law enforcement purposes, etc. >* Reports made to the Food and Drug Administration (FDA) >* Information provided to funeral directors >* Organ procurement >* Information released based on a subpoena or court order > >-----Original Message----- >From: Nancy Jones [mailto:[EMAIL PROTECTED]] >Sent: Tuesday, August 27, 2002 10:37 AM >To: [EMAIL PROTECTED] >Cc: 'Noel, Linda A.'; [EMAIL PROTECTED] >Subject: Re: Accounting of Disclosures: > > >If we receive a request for an accounting, and we do not have to include >disclosures made for treatment, payment, or operations, or disclosures >made because a signed consent or authorization is in place for that >disclosure (marketing, disability determination, etc), what's left? >Seems to me, the only thing left is mistakes. Please let me know if I >am missing something here. > >Nancy Jones >HIPAA Project Mgr. >Nacogdoches Memorial Hospital >Nacogdoches, Texas > > > > "Bentz-Miller, Judith" wrote: > > > > I am currently looking for software for the accounting of disclosures > > that we can use clinic (1200 employees, 26 sites, 150 docs) for the > > log. any suggestions are appreciated. > > > > We are going to use the same support process that we use for the > > authorization requests (FMLAs, etc...) The process is already set up, > > it will just be adding this responsibility to the list. > > > > -----Original Message----- > > From: Noel, Linda A. [mailto:[EMAIL PROTECTED]] > > Sent: Tuesday, August 27, 2002 6:54 AM > > To: [EMAIL PROTECTED] > > Subject: Accounting of Disclosures: > > > > Would anyone be willing to share how they plan to implement > > the "accounting of disclosures"? Also, the point of entry > > for the patient's request -- who will own the process within > > the facility. We are a large organization with 6 hospitals, > > physician practices and clinics. We do not have one central > > computer system. > > > > Linda Noel > > Corporate Privacy Officer > > Corporate Compliance > > Orlando Regional Healthcare > > 321-843-8693 > > > > 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/. > > Posting of advertisements or other commercial use of this > > listserv is > > specifically prohibited. > > > > 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/. > > Posting of advertisements or other commercial use of this listserv is > > specifically prohibited. > >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/. >Posting of advertisements or other commercial use of this listserv is >specifically prohibited. > > > > > > >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/. >Posting of advertisements or other commercial use of this listserv is >specifically prohibited. > >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/. >Posting of advertisements or other commercial use of this listserv is >specifically prohibited. > > > > > > >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/. >Posting of advertisements or other commercial use of this listserv is >specifically prohibited. Christopher J. Feahr, OD http://visiondatastandard.org [EMAIL PROTECTED] Cell/Pager: 707-529-2268 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/. Posting of advertisements or other commercial use of this listserv is specifically prohibited.
