Privacy Certification
Health care industry groups to explore HIPAA privacy certification http://webster.disa.org/dailywire/S20030313_05.html 13 March 2003 -- The National Committee for Quality Assurance (NCQA) and the Joint Commission on Accreditation of Healthcare Organizations (JCAHO) today announced a Letter of Intent to explore a collaboration to offer a Privacy Certification Program for Business Associates. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 --- 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
Fraud and PHI
A federal judge recently ruled that a group of Louisiana physicians accused of overbilling Medicare and Medicaid can remove all patient- identifying information from billing and medical records relevant to the case Visit http://www.AISHealth.com/GNOW/030303.html#gnowseven for more information. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 --- 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: Another thread on Security/Privacy question
Title: RE: Another thread on Security/Privacy question Roy, I would agree with your conclusions with regard to HIPAA but you will probably none the less need a privacy agreement with the collections agency not to disclose or sell credit card information. The FTC does not look too favorably on the disclosure of credit card information. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 -Original Message- From: Clay, Roy III (NO) [mailto:[EMAIL PROTECTED]] Sent: Monday, March 03, 2003 8:42 AM To: WEDI SNIP Privacy Workgroup List Subject: RE: Another thread on Security/Privacy question The name and the credit card number are not PHI under HIPAA. It does not become PHI until some health information is added. If the information contains CPT codes, for example, then you would either need to include that information in the Notice of Privacy Practices or obtain an authorization at the time of swiping the card. One of the questions we had to answer was if the collection agency we used to collect bad debt was a busness associate. We found that all they needed was the guarantor's contact information and an amount. No health information was needed for them to perform their task. Therefore they were not a business associate. Roy G. Clay III Interim Compliance Officer Louisiana State University Health Sciences Center New Orleans Campus Phone: (504) 568-4367 Fax: (504) 568-6378 Email: [EMAIL PROTECTED] -Original Message- From: Christine Hudnall [mailto:[EMAIL PROTECTED]] Sent: Friday, February 28, 2003 2:36 PM To: WEDI SNIP Privacy Workgroup List Subject: Another thread on Security/Privacy question I'm sending this out again, if someone could please help us. Thanks. Christine What about the card swipes that we use when a patient makes a payment on their account using their credit card. Yes, we only swipe the card and put in the last four digits of the number, but the patient name (or whoever owns the card) prints out on the receipt. Is that considered PHI, even though we are not sending them the name, but they print it from their records? If so, do we need to have an agreement with the company that we use the card swipe from? And as for eligibility, i.e., Medicaid. We use ROVR, which is through Consultec (if I remember correctly). Is an agreement needed with them? And how would I check for security for their program? Is that something they would need to do and put in writing? Sorry for all the questions, just, my co-worker and I are trying to go down list of all possibilities that we need to check on. Thanks, Christine _ Help STOP SPAM with the new MSN 8 and get 2 months FREE* http://join.msn.com/?page=features/junkmail --- 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 --- The WEDI SNIP listserv to which you
'Do Not Call' follow-up
ATT Government Solutions Awarded $3.5 Million Contract by FTC to Develop And Implement 'Do Not Call' Registry Consumer Registration Expected This Summer VIENNA, Va., Feb 26, 2003 /PRNewswire-FirstCall via COMTEX/ -- ATT Government Solutions announced today it has been awarded a $3.5 million contract from the Federal Trade Commission to develop and implement a national registry containing phone numbers of consumers who do not wish to be contacted by telemarketers http://www.govcon.com/nl/14406/11100 Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 --- 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: medical vendors as Business Associates
Doug, Does your facility do medical device implants? If so, do you know what the official position is of your facility on this? Thanks. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools 612-237-1966 -Original Message- From: Doug Webb [mailto:[EMAIL PROTECTED]] Sent: Wednesday, February 26, 2003 11:29 AM To: WEDI SNIP Privacy Workgroup List Subject: Re: medical vendors as Business Associates Vicki, I believe that in this case the vendor would a Healthcare Providerparticipating in Treatment.They would not be a BA. They would be a CE if they used any of the standard electronic transactions. The opinions expressed here are my own and not necessarily the opinion of LCMH. Douglas M. Webb Computer System Engineer Little Company of Mary Hospital Health Care Centers [EMAIL PROTECTED] This electronic message may contain information that is confidential and/or legally privileged. It is intended only for the use of the individual(s) and entity(s) named as recipients in the message. If you are not an intended recipient of the message, please notify the sender immediately, delete the material from any computer, do not deliver, distribute, or copy this message, and do not disclose its contents or take action in reliance on the information it contains. Thank you. - Original Message - From: Vicki Schaff To: Doug Webb Sent: Wednesday, February 26, 2003 10:53 AM Subject: Re: medical vendors as Business Associates Consider the vendor who supplies anew medical deviceto ahealthcare facility (CE)and the vendorprovides instruction to a surgeon (CE)during implantation of the device. The vendor has access to PHI.One legal opinion has stated that thevendor is a BA of the healthcare facility. Your Comments. - Original Message - From: Doug Webb To: WEDI SNIP Privacy Workgroup List Sent: Wednesday, February 26, 2003 9:29 AM Subject: Re: medical vendors as Business Associates Jill, I agree with Dan. The critical question is do you do anything on behalf of a Covered Entity that involves PHI? If this answer is No, you do not need a BAA. Providing devices to non-patients isolates you from PHI. Providing devices to patients is acting on behalf of yourself (I assume you make a profit on the deal, or you wouldn't be in business), not a service to the Covered Entity. If you also bill insurance carriers electronically, you may be a Covered Entity (providing Treatment). As Dan said, it would be extremely rare that a vendor of this type would be in a Business Associate relationship with a Covered Entity. If it operates in some other role in addition to being a DME vendor, that role must be considered independantly. . The opinions expressed here are my own and not necessarily the opinion of LCMH. Douglas M. Webb Computer System Engineer Little Company of Mary Hospital Health Care Centers [EMAIL PROTECTED] This electronic message may contain information that is confidential and/or legally privileged. It is intended only for the use of the individual(s) and entity(s) named as recipients in the message. If you are not an intended recipient of the message, please notify the sender immediately, delete the material from any computer, do not deliver, distribute, or copy this message, and do not disclose its contents or take action in reliance on the information it contains. Thank you. - Original Message - From: Dan Kelsey To: WEDI SNIP Privacy Workgroup List Sent: Wednesday, February 26, 2003 08:32 AM Subject: RE: medical vendors as Business Associates I think your decision would have to be very fact based. For example, if a wheelchair company sells 50 wheelchairs to a hospital, then they would not be a BA of the hospital. However, if the hospital rehab unit orders a custom fit wheelchair that involves disclosure of the patient's limitations, physical build, etc., then chances are a BA relationship does not exist either. I say chances are because treatment by a health care provider is exempt from the BA definition and a BAA is not required. The key issue is if the medical vendor meets the definition of a health care provider - there is a mention in HIPAA for the Federal definition, and it is fairly all encompassing. Generally speaking, I do not think the majority of these vendors would be business associates. Hope this helps, Dan Kelsey Practice Advisor Indiana State Medical Association 800-257-4762 (317) 261-2060 (317) 261-2076 - fax -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Sent: Wednesday, February 26, 2003 7:42 AM To: WEDI SNIP Privacy Workgroup List Subject: medical vendors as Business Associates
RE: medical vendors as Business Associates
Doug, This discussion has appeared on other healthcare listservs and there seems to be a strong leaning towards having medical device manufacture reps be considered part of TPO. It brings up an interesting liability issue as well as a patient consent issue for reps being in the OR. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 -Original Message- From: Doug Webb [mailto:[EMAIL PROTECTED]] Sent: Wednesday, February 26, 2003 2:53 PM To: David Frenkel; WEDI SNIP Privacy Workgroup List Subject: Re: medical vendors as Business Associates David, They do, but I'm not directly involved, so I don't know the answer to your question. Jim Hewitt did bring up an interesting point that these vendors may also be hardware/software support people. In that role, I would think that a BAA would be appropriate to state that they would protect PHI they contact while maintaining the equipment. I had been thinking just of their role as a supplier of the equipment. Whew! Covering all bases is tough!. The opinions expressed here are my own and not necessarily the opinion of LCMH. Douglas M. Webb Computer System Engineer Little Company of Mary Hospital Health Care Centers [EMAIL PROTECTED] This electronic message may contain information that is confidential and/or legally privileged. It is intended only for the use of the individual(s) and entity(s) named as recipients in the message. If you are not an intended recipient of the message, please notify the sender immediately, delete the material from any computer, do not deliver, distribute, or copy this message, and do not disclose its contents or take action in reliance on the information it contains. Thank you. - Original Message - From: David Frenkel To: WEDI SNIP Privacy Workgroup List Sent: Wednesday, February 26, 2003 02:10 PM Subject: RE: medical vendors as Business Associates Doug, Does your facility do medical device implants? If so, do you know what the official position is of your facility on this? Thanks. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools 612-237-1966 -Original Message- From: Doug Webb [mailto:[EMAIL PROTECTED] Sent: Wednesday, February 26, 2003 11:29 AM To: WEDI SNIP Privacy Workgroup List Subject: Re: medical vendors as Business Associates Vicki, I believe that in this case the vendor would a Healthcare Providerparticipating in Treatment.They would not be a BA. They would be a CE if they used any of the standard electronic transactions. The opinions expressed here are my own and not necessarily the opinion of LCMH. Douglas M. Webb Computer System Engineer Little Company of Mary Hospital Health Care Centers [EMAIL PROTECTED] This electronic message may contain information that is confidential and/or legally privileged. It is intended only for the use of the individual(s) and entity(s) named as recipients in the message. If you are not an intended recipient of the message, please notify the sender immediately, delete the material from any computer, do not deliver, distribute, or copy this message, and do not disclose its contents or take action in reliance on the information it contains. Thank you. - Original Message - From: Vicki Schaff To: Doug Webb Sent: Wednesday, February 26, 2003 10:53 AM Subject: Re: medical vendors as Business Associates Consider the vendor who supplies anew medical deviceto ahealthcare facility (CE)and the vendorprovides instruction to a surgeon (CE)during implantation of the device. The vendor has access to PHI.One legal opinion has stated that thevendor is a BA of the healthcare facility. Your Comments. - Original Message - From: Doug Webb To: WEDI SNIP Privacy Workgroup List Sent: Wednesday, February 26, 2003 9:29 AM Subject: Re: medical vendors as Business Associates Jill, I agree with Dan. The critical question is do you do anything on behalf of a Covered Entity that involves PHI? If this answer is No, you do not need a BAA. Providing devices to non-patients isolates you from PHI. Providing devices to patients is acting on behalf of yourself (I assume you make a profit on the deal, or you wouldn't be in business), not a service to the Covered Entity. If you also bill insurance carriers electronically, you may be a Covered Entity (providing Treatment). As Dan said, it would be extremely rare that a vendor of this type would be in a Business Associate relationship with a Covered Entity. If it operates in some other role in addition to being a DME vendor, that role must be considered independantly. . The opinions
RE: DOL vs. HIPAA
David, You have a good suggestion but unfortunately it is not all that uncommon for government legislation to conflict between federal agencies and departments. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 -Original Message- From: David Blasi [mailto:[EMAIL PROTECTED]] Sent: Friday, February 21, 2003 8:16 AM To: WEDI SNIP Privacy Workgroup List Subject: Re: DOL vs. HIPAA I would just add that I hope that if CMS decides to expand on this in a QA or in whatever manner they choose that they consult with their counterparts at the DOL. I have made comments several times about the discrepancy between HIPAA and ERISA. It benefits everyone if as much information about how claims were paid are included on an EOB. That is ERISA's goal. Very simply the HIPAA concerns can be addressed by the patient having the EOB sent to an alternative address or requiring that it be addressed to the patient. It is then up to the patient to control their own PHI. A health plan should not be responsible for someone opening another person's mail. David Ermer [EMAIL PROTECTED] 02/20/03 07:37PM Michele -- I am not aware of any HHS statement in the 12/28/2000 preamble to the effect that diagnosis information must be stripped from the EOB in order to achieve Privacy Rule compliance. I have quoted the relevant preamble statements below my signature. Although HHS has not issued any dictates about the substance of the EOB, it's important to recall that payment communications such as the EOB are subject to the minimum necessary rule. Consequently, if it's not necessary to communicate the diagnosis to achieve the purpose of the communication, then the diagnosis shouldn't be included. Getting to your question, a valid purpose of the EOB is communicate payment information in compliance with with ERISA. Therefore, in my opinion, if ERISA requires disclosure of the diagnosis in a particular situation, e.g, at the appeal stage, the disclosure of the diagnosis on the EOB would fit within the minimum necessary standard. I do agree with you that it would be helpful for DOL to provide official guidance integrating the claims processing rule with the Privacy Rule. Best regards, Dave Ermer P.S. Here are the 12/28/00 preamble statements that I found: Comment: A commenter noted that the definition of disclosure should reflect that health plan correspondence containing protected health information, such as Explanation of Benefits (EOBs), is frequently sent to the policyholder. Therefore, it was suggested that the words provision of access to be deleted from the definition and that disclosure be clarified to include the conveyance of protected health information to a third party. Response: The definition is, on its face, broad enough to cover the transfers of information described and so is not changed. We agree that health plans must be able to send EOBs to policyholders. Sending EOB correspondence to a policyholder by a covered entity is a disclosure for purposes of this rule, but it is a disclosure for purposes of payment. Therefore, subject to the provisions of ยง 164.522(b) regarding Confidential Communications, it is permitted even if it discloses to the policyholder protected health information about another individual (see below). Comment: Certain commenters explained that third party administrators usually communicate with employees through Explanation of Benefit (EOB) reports on behalf of their dependents (including those who might not be minor children). Thus, the employee might be apprized of the medical encounters of his or her dependents but not of medical diagnoses unless there is an over-riding reason, such as a child suspected of drug abuse due to multiple prescriptions. The commenters urged that the current claim processing procedures be allowed to continue. Response: We agree. We interpret the definition of payment and, in particular the term 'claims management,' to include such disclosures of protected health information. Comment: One commenter requested that we create a standard that all information from a health plan be sent to the patient and not the policyholder or subscriber. Response: We require health plans to accommodate certain requests that information not be sent to a particular location or by particular means. A health plan must accommodate reasonable requests by individuals that protected health information about them be sent directly to them and not to a policyholder or subscriber, if the individual states that he or she may be in danger from disclosure of such information. We did not generally require health plans to send information to the patient and not the policyholder or subscriber because we believed it would be administratively burdensome and because the named insured may have a valid need for such information to manage payment and benefits. Gordon Barnett 1133 21st St., NW, Suite 450 Washington, DC
Archiving Emails
I think there was an earlier discussion on archiving emails. VENDORS UNITE TO OFFER E-MAIL ARCHIVING SOLUTIONS Bringing together components from each provider, EMC, Iron Mountain and KVS aim to save users time and money when implementing e-mail archiving solutions. For the full story, click http://update.wallstreetandtech.com/cgi-bin4/flo?y=eKcs0B1w560V50BrCD0AV ___ Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 612-237-1966 --- 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: archive@mail-archive.com 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
JCAHO BA resource
New Tools Now Available on Jayco The Joint Commission's extranet for health care organizations, Jayco, will be a key source of information and communication throughout 2003 and under the 2004 accreditation process Shared Visions-New Pathways. Jayco now houses a model HIPAA business associate agreement for review on HIPAA regulations for the Standards for Privacy of Individually Identified Health Information, which will be effective in April 2003. The Jayco site enables electronic signature and submission by health care organizations of this agreement. And beginning in February, accreditation reports, with confidential survey information including details of the organization's requirements for improvement and status, will become available on Jayco. This information will only be available to the health care organization itself or, if it is part of a system, the corporate office. Complete story: http://www.jcaho.org/About+Us/News+Letters/JCAHOnline/jo_01_03.htm#jayco Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 --- 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: archive@mail-archive.com 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: HIPAA-related privacy question (I think)
--- You are currently subscribed to wedi-privacy as: archive@jab.org 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 --- If you follow healthcare politics a number of organizations including the AHA are lobbying in DC to get politicians on record about their positions on hospital funding via Medicare reimbursements. Congress intended HIPAA to long term save money so by trying to avoid Congress in one sense and then asking for higher reimbursements seems to be a political conflict. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 -Original Message- From: KERBER, JEFF [mailto:JKERBER;THCS.ORG] Sent: Tuesday, October 22, 2002 2:06 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: HIPAA-related privacy question (I think) --- 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 --- Many providers are thinking that if they go paper only, they can get around HIPAA... Only problem is, the federal programs are going to require electronic submission. At that time, the provider either opts out of MediCxxx programs to avoid complying with HIPAA or face becoming compliant. -Original Message- From: Sparma, Deborah, nashccon [mailto:Deborah.Sparma.nashccon;acs-inc.com] Sent: Tuesday, October 22, 2002 3:37 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: HIPAA-related privacy question (I think) I appreciate the clarifications. However, my next question becomes this the definition of Health Care information in the rule is as follows: Health information means any information, whether oral or recorded in any form or medium, that: (1) Is created or received by a health care provider, health plan, public health authority, employer, life insurer, school or university, or health care clearinghouse; and (2) Relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual. If health care information can be in ANY form and covered under the privacy rule, then why is it only providers who submit electronic transaction that are covered entities. Wouldn't the providers choose NOT to conduct an electronic transaction still have Health Care information as defined in the rule? Are you telling me there are totally exempt of this privacy rule because they are not conducting an electronic transaction, BUT they have health information in any form? Deborah This electronic message may contain information that is confidential and/or legally privileged. It is intended only for the use of the individual(s) and entity named as recipients in the message. If you are not an intended recipient of the message, please notify the sender immediately and delete the material from any computer. Do not deliver, distribute, or copy this message, and do not disclose its contents or take action in reliance on the information it contains. Thank you. --- 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. --- 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.
RE: HIPAA-related privacy question (I think)
--- You are currently subscribed to wedi-privacy as: archive@jab.org 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 --- F.W., You might be interested in this from Tuesdays AHA email news. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 Hospital groups launch congressional pledge campaign Eight national hospital groups, including the AHA, today launched a nationwide campaign to get federal legislators on record as supporting substantial hospital payment relief and opposing adjournment of the 107th Congress until such relief is enacted. Pointing out that the Senate and the House recessed to prepare for the Nov. 5 elections without completing action on a hospital provider payment relief package, even though there is significant Capitol Hill support for such action and the House earlier passed relief legislation, the groups in a joint Grassroots Alert called on hospital leaders to ask their senators and representatives to sign a pledge titled My Commitment to My Community's Hospitals while legislators are on the campaign trail. The pledge states, in part, Hospitals in my community, and hospitals all across America, require immediate federal relief in order to continue to provide the high-quality health care services their patients and communities need Therefore, Congress should not vote to adjourn until we have passed and the President has signed legislation providing substantial Medicare and Medicaid provider payment improvements -- at least at the level included in H.R. 4954 or S. 3018 -- for America's hospital and the patients they serve. Included with the pledge is a return fax number, so that the pledges can be delivered to President Bush and House or Senate leaders. Joining in the effort are AHA, the Association of American Medical Colleges, the Catholic Health Association of the United States, the Federation of American Hospitals, the National Association of Children's Hospitals, the National Association of Public Hospitals and Health Systems, Premier and VHA. State, regional and metropolitan hospital associations also are working closely with the national associations on the campaign. The pledge was provided to all hospitals in the country. -Original Message- From: fwdanby [mailto:fwdanby;grolen.com] Sent: Tuesday, October 22, 2002 3:12 PM To: WEDI SNIP Privacy Workgroup List Subject: Re: HIPAA-related privacy question (I think) --- 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 --- KERBER, JEFF [EMAIL PROTECTED] Wrote: Many providers are thinking that if they go paper only, they can get around HIPAA... Only problem is, the federal programs are going to require electronic submission. At that time, the provider either opts out of MediCxxx programs to avoid complying with HIPAA or face becoming compliant. If the current worsening trend in MediCxxx reimbursement continues, the enforcement of electronic submission will be an added stimulus to cease to be a participant in these programs. Have any of you pointed this out to AARP? F. W. Danby, MD --- 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. --- 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.
RE: Transaction Extension Plan
--- You are currently subscribed to wedi-privacy as: archive@jab.org 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 --- Noel, These TCS issues have been discussed on the WEDI transactions listserv. The privacy portion of HIPAA will be handled by the HHS Office of Civil Rights (OCR). Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 -Original Message- From: Noel Chang [mailto:nchang;integralps.com] Sent: Monday, October 21, 2002 6:34 PM To: WEDI SNIP Privacy Workgroup List Subject: Re: Transaction Extension Plan --- 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 --- If the part of the CMS web site that allowed you to submit an extension application has been disabled, see if you can still get into their Frequently Asked Questions section (I have not tried). I know they have answered this question. Basically (if memory serves) their answer was the provider will have to comply with the transaction standards ASAP and may be asked to submit a compliance plan showing how they intend to do so. I do not recall seeing anything about fines or penalties at this point. There also was an announcement from CMS recently that said they had been named the enforcement body for the transaction and code set standards. In that communication they indicated that their initial approach to enforcement was going to be to first seek voluntary compliance before issuing any fines. Definitely look for the FAQ on this at the CMS web site but I think they will be OK. -- Open WebMail Project (http://openwebmail.org) -- Original Message --- From: Nancy Jones [EMAIL PROTECTED] To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED] Sent: Mon, 21 Oct 2002 14:05:27 -0500 Subject: Transaction Extension Plan --- 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 --- This is a multi-part message in MIME format. --- End of Original Message --- --- 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. --- 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.
RE: Transaction Extension Plan
--- You are currently subscribed to wedi-privacy as: archive@jab.org 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 --- from AHA email news 10/16/02 CMS logs half-million applications for HIPAA deadline extension The Centers for Medicare Medicaid Services today said it has received more than 500,000 applications for a one-year extension of the Oct. 15 deadline for complying with the Health Insurance Portability and Accountability Act's transactions and code sets standards. HIPAA-covered entities, which include hospitals, that did not apply for the extension are expected to be in compliance with the transactions and code sets regulation as of today. On Oct. 15, CMS announced it would create a new office within the agency to handle HIPAA regulatory compliance. For more, go to http://www.hhs.gov/news/press/2002pres/20021015a.html. Regards, David Frenkel Business Development GEFEG USA Global Leader in Ecommerce Tools www.gefeg.com 425-260-5030 -Original Message- From: fwdanby [mailto:fwdanby;grolen.com] Sent: Monday, October 21, 2002 8:10 PM To: WEDI SNIP Privacy Workgroup List Subject: Re: Transaction Extension Plan --- 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 --- Any idea how many of the nation's providers have complied / not complied? I think I was 487 or something like that. Who is counting? Nice job for somebody's electoral district, huh? If they will allow an extension by simple application why not just move the date back for everyone? Administrative Simplification? I beg to differ. F.W.Danby, MD --- 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. --- 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.
