PRIVACY: NPP Distribution
Title: PRIVACY: NPP Distribution It is a health plans responsibility to distribute the NPP to their subscribers. I have heard that some plans are providing the notice to the groups and asking them to distribute to their employees. This leaves the liability if the groups do not distribute on the plans. I'm trying to get an idea of how many plans are doing it this way. I feel we should mail them out to the subscribers even though it is costly. But I would like to get an idea of the rest of the industry. Thank you! Deborah Campbell Compliance Coordinator Dominion Dental Services, Inc. 115 South Union Street, Suite 300 Alexandria, Virginia 22314 Phn: (703) 518-5000 ext. 3035 Fax: (703) 518-8849 Toll Free: 888-518-5338 Email: [EMAIL PROTECTED] *** The information in this email is confidential and may be legally privileged. It is intended solely for the addressee. Access to this email by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful. * --- 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
Department of Health BAA
I have seen this asked prior, but remain confused Following the same line of JCAHO we should be getting BA's from the Department of Health if they are our reviewing/governing body? Or since they are a public entity we do not? It would make sense for them to follow in the footsteps of JCAHO and have us complete their BAA form -Original Message- From: Teri Baskett [mailto:[EMAIL PROTECTED] Sent: Wednesday, March 05, 2003 8:31 AM To: WEDI SNIP Privacy Workgroup List Subject: JCAHO BAA On that BA thread, we just recieved a letter from JCAHO wanted us to complete their BAA form. Following previous messages, shouldn't I (since I'm the CE) be sending them our form, and we shouldn't be signing their's? Teri Baskett, CISO LifeSpring [EMAIL PROTECTED] --- 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 --- 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
RE: PRIVACY: NPP Distribution
Title: PRIVACY: NPP Distribution Hello all-at Wellmark Blue Cross Blue Shield of Iowa, we elected to send the NOPP to our fully-insured contract holders directly. Its also posted on our website. We took the opportunity of this mailing to include a flyer for members promoting the new on-line self services that we are rolling out to them this spring. Marilyn Musser Provider Relations Manager HIPAA-AS Communications Office Wellmark, Inc. phone: 515.248.5588 fax: 515.245.4620 [EMAIL PROTECTED] -Original Message- From: Deborah Campbell [mailto:[EMAIL PROTECTED] Sent: Monday, March 10, 2003 9:42 AM To: WEDI SNIP Privacy Workgroup List Subject: PRIVACY: NPP Distribution It is a health plans responsibility to distribute the NPP to their subscribers. I have heard that some plans are providing the notice to the groups and asking them to distribute to their employees. This leaves the liability if the groups do not distribute on the plans. I'm trying to get an idea of how many plans are doing it this way. I feel we should mail them out to the subscribers even though it is costly. But I would like to get an idea of the rest of the industry. Thank you! Deborah Campbell Compliance Coordinator Dominion Dental Services, Inc. 115 South Union Street, Suite 300 Alexandria, Virginia 22314 Phn: (703) 518-5000 ext. 3035 Fax: (703) 518-8849 Toll Free: 888-518-5338 Email: [EMAIL PROTECTED] *** The information in this email is confidential and may be legally privileged. It is intended solely for the addressee. Access to this email by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful. * --- 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 --- 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
named Privacy officer on NPP, posting
I have two quick questions for the group: 1. When your Notice of Privacy Practices (NPP) says to contact the Privacy Officer for such and such, does the Privacy Officer need to be a NAMED individual or can you just list the title of the contact person (e.g., the Privacy Officer)? 2.Since the law calls for a posting of the NPP, can we display a stapled copy of our 6 page NPP in a locked bulletin board (which would then just show the first page of the NPP) and then have a sign next to this displayed NPP that tells the inquisitive patient where in our office they can get a complete copy of the NPP if they wish? I realize that this proposal probably goes against the intent of this provision of the law but would it be technically be sufficient to meet the requirements of this provision? Reasons behind such a proposal are 1. Space is a problem, 2. Hanging up a 6-8 page NPP looks trashy. 3. All patient's will be personally handed the NPP so what's the point of posting it anyway? 4. And we would be posting it, it's just that you could not read all the pages of the posted version! Thanks for all advice provided. Rich Fairley --- 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
RE: named Privacy officer on NPP, posting
Title: RE: named Privacy officer on NPP, posting 1) yes, you can just list the title of the Privacy Officer. That is what we are doing. Otherwise you have to redistribute every time your Privacy Officer changes. 2) I don't think this meets the requirements. But I'd see what everyone else says. Deborah Campbell Compliance Coordinator Dominion Dental Services, Inc. 115 South Union Street, Suite 300 Alexandria, Virginia 22314 Phn: (703) 518-5000 ext. 3035 Fax: (703) 518-8849 Toll Free: 888-518-5338 Email: [EMAIL PROTECTED] *** The information in this email is confidential and may be legally privileged. It is intended solely for the addressee. Access to this email by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful. * -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Monday, March 10, 2003 12:39 PM To: WEDI SNIP Privacy Workgroup List Subject: named Privacy officer on NPP, posting I have two quick questions for the group: 1. When your Notice of Privacy Practices (NPP) says to contact the Privacy Officer for such and such, does the Privacy Officer need to be a NAMED individual or can you just list the title of the contact person (e.g., the Privacy Officer)? 2. Since the law calls for a posting of the NPP, can we display a stapled copy of our 6 page NPP in a locked bulletin board (which would then just show the first page of the NPP) and then have a sign next to this displayed NPP that tells the inquisitive patient where in our office they can get a complete copy of the NPP if they wish? I realize that this proposal probably goes against the intent of this provision of the law but would it be technically be sufficient to meet the requirements of this provision? Reasons behind such a proposal are 1. Space is a problem, 2. Hanging up a 6-8 page NPP looks trashy. 3. All patient's will be personally handed the NPP so what's the point of posting it anyway? 4. And we would be posting it, it's just that you could not read all the pages of the posted version! Thanks for all advice provided. Rich Fairley --- 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 --- 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
Re: named Privacy officer on NPP, posting
I agree with Deborah's response to both questions. At the HHS/OCR conference in Atlanta a few weeks ago, Richard Campanelli (Director of OCR) made it very clear that: If you don't get a Notice you haven't been provided with your rights. Also, that Notice on the wall is not enough. He stated that the Privacy Rule's intention is that a direct treatment provider would provide each patient with a copy of the NPP - it has contact information on it and the individual should be able to take it home and read it. Mr. Campanelli was quite clear as to a CE's obligations relative to the NPP and that OCR would not look kindly on a CE who tried to cut corners. Jean Acevedo, LHRM, CPC, CHC. In a message dated 3/10/2003 12:51:32 PM Eastern Standard Time, [EMAIL PROTECTED] writes: 1) yes, you can just list the title of the Privacy Officer. That is what we are doing. Otherwise you have to redistribute every time your Privacy Officer changes. 2) I don't think this meets the requirements. But I'd see what everyone else says. Deborah Campbell Compliance Coordinator Dominion Dental Services, Inc. 115 South Union Street, Suite 300 Alexandria, Virginia 22314 Phn: (703) 518-5000 ext. 3035 Fax: (703) 518-8849 Toll Free: 888-518-5338 Email: [EMAIL PROTECTED] *** The information in this email is confidential and may be legally privileged. It is intended solely for the addressee. Access to this email by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful. * -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Sent: Monday, March 10, 2003 12:39 PM To: WEDI SNIP Privacy Workgroup List Subject: named Privacy officer on NPP, posting I have two quick questions for the group: 1. When your Notice of Privacy Practices (NPP) says to contact the Privacy Officer for such and such, does the Privacy Officer need to be a NAMED individual or can you just list the title of the contact person (e.g., the Privacy Officer)? 2.Since the law calls for a posting of the NPP, can we display a stapled copy of our 6 page NPP in a locked bulletin board (which would then just show the first page of the NPP) and then have a sign next to this displayed NPP that tells the inquisitive patient where in our office they can get a complete copy of the NPP if they wish? I realize that this proposal probably goes against the intent of this provision of the law but would it be technically be sufficient to meet the requirements of this provision? Reasons behind such a proposal are 1. Space is a problem, 2. Hanging up a 6-8 page NPP looks trashy. 3. All patient's will be personally handed the NPP so what's the point of posting it anyway? 4. And we would be posting it, it's just that you could not read all the pages of the posted version! Thanks for all advice provided. Rich Fairley --- 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 --- 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
RE: named Privacy officer on NPP, posting
Mr. Fairley, in response to your question #2: I am not an attorney, but I would advise that any time you are taking an action that you realize is probably against the intent of the law, even if it may successfully be argued to technically meet the requirements of the law, is bad policy. Especially if there is an alternative that can cost-effectively meet the requirement. I have worked with clients who have taken their proposal, also approximately 6 pages, and had it turned into a poster format. It contained all the same information, and even in the same order, but headings, fonts, and column sizes were modified to make a convenient professional looking poster. This option may or may not solve your space issue, but it will clearly meet the posting requirement in a manner which is not trashy. Regards, Jay Astle HIPAA Consultant Unisys Corporation 703-556-5946 -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Sent: Monday, March 10, 2003 12:39 PM To: WEDI SNIP Privacy Workgroup List Subject: named Privacy officer on NPP, posting I have two quick questions for the group: 1. When your Notice of Privacy Practices (NPP) says to contact the Privacy Officer for such and such, does the Privacy Officer need to be a NAMED individual or can you just list the title of the contact person (e.g., the Privacy Officer)? 2.Since the law calls for a posting of the NPP, can we display a stapled copy of our 6 page NPP in a locked bulletin board (which would then just show the first page of the NPP) and then have a sign next to this displayed NPP that tells the inquisitive patient where in our office they can get a complete copy of the NPP if they wish? I realize that this proposal probably goes against the intent of this provision of the law but would it be technically be sufficient to meet the requirements of this provision? Reasons behind such a proposal are 1. Space is a problem, 2. Hanging up a 6-8 page NPP looks trashy. 3. All patient's will be personally handed the NPP so what's the point of posting it anyway? 4. And we would be posting it, it's just that you could not read all the pages of the posted version! Thanks for all advice provided. Rich Fairley --- 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 --- 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
RE: named Privacy officer on NPP, posting
Agree with all on this as well although we are listing my name on the NPP... Thomas L. Johnson Vice President, External Affairs and Compliance D.C. Chartered Health Plan 820 First Street, N.E. Suite LL100 Washington, DC 20002 (p) 202-408-2034 (f) 202-408-0838 -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Sent: Monday, March 10, 2003 1:30 PM To: WEDI SNIP Privacy Workgroup List Subject: Re: named Privacy officer on NPP, posting I agree with Deborah's response to both questions. At the HHS/OCR conference in Atlanta a few weeks ago, Richard Campanelli (Director of OCR) made it very clear that: If you don't get a Notice you haven't been provided with your rights. Also, that Notice on the wall is not enough. He stated that the Privacy Rule's intention is that a direct treatment provider would provide each patient with a copy of the NPP - it has contact information on it and the individual should be able to take it home and read it. Mr. Campanelli was quite clear as to a CE's obligations relative to the NPP and that OCR would not look kindly on a CE who tried to cut corners. Jean Acevedo, LHRM, CPC, CHC. In a message dated 3/10/2003 12:51:32 PM Eastern Standard Time, [EMAIL PROTECTED] writes: 1) yes, you can just list the title of the Privacy Officer. That is what we are doing. Otherwise you have to redistribute every time your Privacy Officer changes. 2) I don't think this meets the requirements. But I'd see what everyone else says. Deborah Campbell Compliance Coordinator Dominion Dental Services, Inc. 115 South Union Street, Suite 300 Alexandria, Virginia 22314 Phn: (703) 518-5000 ext. 3035 Fax: (703) 518-8849 Toll Free: 888-518-5338 Email: [EMAIL PROTECTED] *** The information in this email is confidential and may be legally privileged. It is intended solely for the addressee. Access to this email by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it is prohibited and may be unlawful. * -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Sent: Monday, March 10, 2003 12:39 PM To: WEDI SNIP Privacy Workgroup List Subject: named Privacy officer on NPP, posting I have two quick questions for the group: 1. When your Notice of Privacy Practices (NPP) says to contact the Privacy Officer for such and such, does the Privacy Officer need to be a NAMED individual or can you just list the title of the contact person (e.g., the Privacy Officer)? 2.Since the law calls for a posting of the NPP, can we display a stapled copy of our 6 page NPP in a locked bulletin board (which would then just show the first page of the NPP) and then have a sign next to this displayed NPP that tells the inquisitive patient where in our office they can get a complete copy of the NPP if they wish? I realize that this proposal probably goes against the intent of this provision of the law but would it be technically be sufficient to meet the requirements of this provision? Reasons behind such a proposal are 1. Space is a problem, 2. Hanging up a 6-8 page NPP looks trashy. 3. All patient's will be personally handed the NPP so what's the point of posting it anyway? 4. And we would be posting it, it's just that you could not read all the pages of the posted version! Thanks for all advice provided. Rich Fairley --- 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 --- 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
MINIMUM NECESSARY
Please comments on these two situations: 1. The request of non-BA public health plan (lets say Plan A) to the State Plan, of eligibility information of the enrollees in the Medicaid program constitutes a minimum necessary violation under HIPAA? 2. Can Plan A be in charge of the eligibility system of the State Plan without been a BA? Thanks ... Jorge Jorge Laguna Oficial Principal de Privacidad y Seguridad (Chief Privacy and Security Officer) Departamento de Salud Tel.: (787) 777-2702 Fax:: (787) 777-2710 --- 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
