RE: Thanking a patient for a referral
And if all else fails, couldn't the doctor send a note to the patient saying. "Thank you for referring your friend." With no name, there is no PHI, right? Deborah Campbell -Original Message-From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]Sent: Thursday, October 30, 2003 9:20 PMTo: WEDI SNIP Privacy Workgroup ListSubject: Re: Thanking a patient for a referralA good old fashioned thank you may now have to be first requested by the doctor when in with the referred patient. If the patient agrees, document a verbal agreement and then send the thank you note. We should not be so worried in this environment, that we either forget or discontinue common courtesies. Julie TomkinsonTOMKINSONHealth Consulting ---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:Misusing quoting HIPAA
I know I have, and I'm sure you all have,
experienced many providers using HIPAA as an excuse for not releasing
information. (I'm not saying it was an excuse in this case. There are a lot of
misunderstandings about the regsand certainly a lot of different
interpretations.) But I just got off the phone yesterday with my mother's
doctor. She called me saying her doctor's officewouldn't give her some
information (about her X-rays) saying HIPAA won't allow it. My blood pressure
skyrocketed.I called the woman and asked what exact section she was citing
of the regulations because I have been "doing" HIPAA for 2 years and can't find
anything on that. I then proceeded to quote several other sections that allow
the release. She started stammering and then admitted she didn't know what
regulation it was or where the policy came from. I suggested she look into it
immediately and stop using HIPAA as an excuse. (I really was furious. There are
so many patientsout there who will just accept that excuse because they
haven't been reading the regulations for years.)
This is not an isolatedcase. I've had
other providers try the same thing on me. But - don't mess with my mother unless
you want the "Wrath of Deborah" to descend upon you. :-)
Thanks for letting me
rant.
Deborah Campbell
-Original Message-From: Doug Webb
[mailto:[EMAIL PROTECTED]Sent: Thursday, October 30, 2003 11:27
AMTo: WEDI SNIP Privacy Workgroup ListSubject: Re:
Collection Accts.
Leslie,
Thank you for a timely and
well-written analysis.
So many bad things happen when
HIPAA is mis-read to restrict information exchange it really isn't
restrict.
The "may" in the regulations
also opens a can of worms, but it has to be emphasized that if the release
that HIPAA says may happen is denied, HIPAA cannot be used as an excuse
for the denial. The denial is either based on the prohibitions of
some other law, or the CE's paranoia.
The opinions expressed here are my own and not
necessarily the opinion of LCMH.
Douglas M. WebbComputer System EngineerLittle
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:
Lbender
To: WEDI SNIP Privacy Workgroup
List
Cc: B BURGESS ; [EMAIL PROTECTED]
Sent: Thursday, October 30, 2003 10:06
AM
Subject: Re: Collection Accts.
Charles et al.:
Funny you should raise this issue in light of the terse cover page
story in this morning's Wall Street Journal entitled, "Hospitals Try Extreme
Measures to Collect Their Overdue Debts." Maybe worth a read if your
blood pressure is lower than you'd likethis a.m.
Your issue underscores the intersection of the federal Fair Debt
Collection Practices Act ("FDCPA"), the Fair Credit Reporting Act ("FCRA"),
and HIPAA. A quick trek to the preamble of the HIPAA privacy
rule and its modifications reveals that the Office for Civil Rights has
indicated in no uncertain terms (despite what the so called "credit repair"
websites reveal) that debt collections, locational activities (skip
tracing), and credit reporting consistent with the FCRA (which data elements
HIPAA tracks in describing what can be credit reported) all fall within the
"P" in TPO (treatment, payment and health care operations) -- whether
undertaken directly by a covered entity or by its collection agency business
associate. OCR's position on this is also in a number of the FAQs on
their website.
Marcallee is correct - if a debtor contacts a credit reporting agency
("CRA") and states that they dispute a debt reported either by a healthcare
provider or its collection agency because it has been paid, the CRA must,
under the FCRA, have the data furnisher ("data furnisher" is either the
provider or collection agency who reported the delinquent account to the
CRA), research it and respond within thirty (30) days (15 U.S.C. Section
1681i). The CRA must also mark the account as "disputed" on any credit
reports released before the verification is complete. If the CRA makes
a business decision not to investigate the consumer's dispute, or
alternatively investigates but the "data furnisher" does n
RE: More Business Associate
Title: RE: More Business Associate Craig, The way I understand this (correct me if I'm wrong guys), if you have a contract in place by October 2002, you have a 1 year extension for the BAA. But the Covered Entity is still responsible for the BA abiding by the BA requirements, even though you have waited another year to get a contract signed. We have decided to go ahead and amend the current contracts anyway. Deborah 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: Craig Moen [mailto:[EMAIL PROTECTED]] Sent: Tuesday, April 01, 2003 10:52 AM To: WEDI SNIP Privacy Workgroup List Subject: More Business Associate Can someone help me understand this a little better: I am reading language about having contracts signed before October of 2002. It seems to states that Business Associate agreements/addendums have an extension to 4-14-04 in these instances? For those that we have verbal agreements with we have to have something in place by 4-14-03. Sounds a little strange, because contracts signed before October 2002 may have confidentiality policies etc, but not necessarily the language required by HIPAA(the way I have read it) Thanks for any clarification Craig Moen Director of Rehabilitation HIPAA Privacy Official THERAPY 2000 Confidential Information This email message is intended only for the person or entity to which it is addressed. Unless otherwise indicated or obvious by the nature of this transmittal, the information contained in this email message is privileged and confidential, intended for the use of the intended recipient (or the employee or agent responsible to deliver to the intended recipient), you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message THERAPY 2000 1881 Sylvan Avenue Suite 210 Dallas, Tx 75208 --- 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: Receipt of PHI
We were trying to deal with this issue and determined that the only way to protect electronic PHI, as 164.530 of the Privacy Rule requires is to eitherencrypt emails or not send emails containing PHI. Out of curiosity (because I'd love to find a way around this) If you are not encrypting, how are you meeting the privacy regulations requirement to protect electronic PHI? Deborah Campbell -Original Message-From: Oriol, Albert [mailto:[EMAIL PROTECTED]Sent: Friday, March 28, 2003 3:19 PMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Receipt of PHI The Privacy rule does not call for encryption. Having said this, at the very least I would inventory thoseinstances and inform the c.e. so that both of you can start working on secure transmission methods. Obviously the sooner you address this the better, but I would say you'd have 2 years to get there if you need to, as far as compliance is concerned. The caveat goes to whatwould be considered"reasonable" a. -Original Message-From: Marcus E. McCrory [mailto:[EMAIL PROTECTED]Sent: Friday, March 28, 2003 12:13 PMTo: WEDI SNIP Privacy Workgroup ListSubject: Receipt of PHI I would appreciate any suggestions on how a business associate should address the receipt of PHI from a covered entity that has been sent across an open network (without encryption) after the Privacy Rule is enforceable. Thank you. Marcus McCrory ---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 CONFIDENTIALITY NOTICE: The information contained in this message is legally priveleged and confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any release, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the author immediately by replying to this message and delete the original message. 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.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
RE: New to this list, have two questions.
Title: RE: New to this list, have two questions. Here's my opinion. I'd be interested if anyone has other opinions. 1) An email is unprotected as soon as it is sent over the internet. Almost anyone can intercept it. So you need to determine your risk and what you want to do to eliminate it. We have determined that no PHI will be sent via email until we have an encryption solution. 2) It depends what the Case Manager is doing. If they are working on behalf of the insurance carrier, then they are either an employee of the carrier or a BA of the carrier. If they are doing Quality Assurance on behalf of the carrier, you are permitted to release PHI to them without the need of any contract with them (the carrier would have the contract). Check § 164.506(c)(4) of the August revisions of the Privacy Rule. Deborah 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 24, 2003 9:25 AM To: WEDI SNIP Privacy Workgroup List Subject: New to this list, have two questions. Hello List, I am new to this list, so please be patient with me, if I ask any questions that have been addressed repeatedly in the past. Anyway, I am the HIPAA Privacy Officer for a Physician's Group Practice and have just recently finished our first round of Privacy Training and Education for the group. Two questions came up that I could not answer specifically: 1) Is there specific direction as to what we can and can not discuss during e-mails between the clinic and patient; and 2) Do we need a contract between Nurse Case Manager's that come in to our office to discuss treatment plans with our doctors (that are contracted by the Insurance Carrier) and our Physician's Group to satisfy Business Associate Policy portion of our HIPAA Privacy Rule policies? I appreciate any information available. Also, please let me know if there are other List-Serves that are more specific to Healthcare Privacy, Security Electronic Transactions. Thank You, Daryl Ewing, CPC RPK Anesthesia, P.A. --- 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: Disclosing Claims Info to Fully-Insured Group Moving to Self- Fund ed
Title: Disclosing Claims Info to Fully-Insured Group Moving to Self-Funded According to what I know about this, you would only be able to provide this type of information to the GHP if they certified to you that they amended their plan documents. But, I might be missing something. 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: Traci.Jensen [mailto:[EMAIL PROTECTED]Sent: Monday, March 24, 2003 11:58 AMTo: WEDI SNIP Privacy Workgroup ListSubject: Disclosing Claims Info to Fully-Insured Group Moving to Self-Fund ed Pursuant to 164.530(k) a group health plan is not subject to the Privacy standards if the group health plan provides health benefits solely through an insurance contract with a health insurance issuer or an HMO and the health insurane issuer or HMO with respect to the group health plan only discloses eligibility, enrollment and disenrollment information and summary information (claims information that doesn't identify a member) to an employer group. My two questions are: If a group health plan of an employer fall under the above definition (fully-insured), however decides to become self-funded, would our organization then be allowed to provide the claims experience by member to the employer in order for them to send to the stop-loss carrier? And, what if the employer is in the process to determine if they want to become self-funded, would our organization be allowed to provide the employer claims experience by member to the employer in order for them to send to the stop-loss carrier? Thank you in advance for your comments. Traci Jensen, CHC Health Alliance Medical Plans, Inc. Compliance Programs Manager This electronic message contains information from Health Alliance Medical Plans, Inc. that may be confidential and/or privileged. This information is intended to be for the use of the individual(s) or entity(ies) named above. If you are not the intended recipient, be aware that copying, disclosure or distribution is strictly prohibited. If you have received this electronic transmission in error, please notify us by telephone at 800-851-3379, ext. 8012 or 4684 or by electronic mail to the sender immediately.---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
RE: BA v Trading Partner Agreements
Title: RE: BA v Trading Partner Agreements The BA is between a CE and another entity that uses or discloses behalf for the CE. A trading partner is between a CE and another entity who exchange transactions electronically stating how you will protect the electronic PHI. Deborah Campbell -Original Message- From: Jonathan May [mailto:[EMAIL PROTECTED]] Sent: Thursday, March 20, 2003 1:44 PM To: WEDI SNIP Privacy Workgroup List Subject: BA v Trading Partner Agreements Can anyone offer a simple clarification of the difference between and when to use a Business Associate Agreement and a Trading Partner Agreement? Many thanks. _ STOP MORE 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
RE: Grievance, Notice of PP
Title: RE: Grievance, Notice of PP I survived another list serve about this same question. We do have to say in the Notice that they can complain directly to the Secretary. But the regs do not say you have to list the contact info for them (you do for your organization.) After asking the other list serve, the majority of people said they were not including the contact info for the Secretary in their Notice. But they would include it in a resolution letter about a complaint and would supply it if they were asked. Hope that helps. 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: Craig Moen [mailto:[EMAIL PROTECTED]] Sent: Tuesday, March 18, 2003 2:35 PM To: WEDI SNIP Privacy Workgroup List Subject: Grievance, Notice of PP On our notice we have listed detailed information on who to contact at our office in the event of a complaint. We also state that the patient may complain directly to the U.S. Secretary of DHHS. 1. Does that need to be listed?(seems like I remember it has to be on the NPP) 2. Do we need to list the address/contact to file a complaint specifically to DHHS as we did to complain to us? Craig Moen Director of Rehab THERAPY 2000 Confidential Information This email message is intended only for the person or entity to which it is addressed. Unless otherwise indicated or obvious by the nature of this transmittal, the information contained in this email message is privileged and confidential, intended for the use of the intended recipient (or the employee or agent responsible to deliver to the intended recipient), you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message THERAPY 2000 1881 Sylvan Avenue Suite 210 Dallas, Tx 75208 --- 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: Grievance, Notice of PP
Title: RE: Grievance, Notice of PP While "surviving" HIPAA is a challenge for us all.I meant to say I "surveyed" another list serve. Guess that wasa Freudian slip. Deborah Campbell -Original Message-From: Deborah Campbell [mailto:[EMAIL PROTECTED]Sent: Tuesday, March 18, 2003 3:34 PMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Grievance, Notice of PP I survived another list serve about this same question. We do have to say in the Notice that they can complain directly to the Secretary. But the regs do not say you have to list the contact info for them (you do for your organization.) After asking the other list serve, the majority of people said they were not including the contact info for the Secretary in their Notice. But they would include it in a resolution letter about a complaint and would supply it if they were asked. Hope that helps. 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: Craig Moen [mailto:[EMAIL PROTECTED]] Sent: Tuesday, March 18, 2003 2:35 PM To: WEDI SNIP Privacy Workgroup List Subject: Grievance, Notice of PP On our notice we have listed detailed information on who to contact at our office in the event of a complaint. We also state that the patient may complain directly to the U.S. Secretary of DHHS. 1. Does that need to be listed?(seems like I remember it has to be on the NPP) 2. Do we need to list the address/contact to file a complaint specifically to DHHS as we did to complain to us? Craig Moen Director of Rehab THERAPY 2000 Confidential Information This email message is intended only for the person or entity to which it is addressed. Unless otherwise indicated or obvious by the nature of this transmittal, the information contained in this email message is privileged and confidential, intended for the use of the intended recipient (or the employee or agent responsible to deliver to the intended recipient), you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message THERAPY 2000 1881 Sylvan Avenue Suite 210 Dallas, Tx 75208 --- 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 uns
RE: A tricky BA Questions
Title: RE: A tricky BA Questions 1) If it is part of the payors Quality Assurance, the payor is allowed to audit a providers records as long as both the payor and the provider have a relationship with the patient. I don't have the citation in front of me, but I can find it. It is listed, in the 8/14/02 revisions, under Use and Disclosure of PHI. If the payor has a BA Agreement with an auditor, the auditor has a right to look at anything the payor has would have a right to look at. 2) The payor would not be a BA of the provider. In order to be a BA the payor would need to be using and disclosing PHI on behalf of the provider. They are not doing that. They are using and disclosing PHI on their own behalf. Just my opinion. 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: Vikas Budhiraja [mailto:[EMAIL PROTECTED]] Sent: Thursday, March 13, 2003 4:05 PM To: WEDI SNIP Privacy Workgroup List Subject: A tricky BA Questions I have been encountered with a tricky BA question and hope someone can provide some insight. Insurance companies engage certain agencies to audit provider records to verify if what the hospital billed was correct and if the insurance company has overpaid. Since these audit agencies are engaged by the Insurance Companies they will be the BA of the Insurance companies. However, they are going to a provider facility to verify the records, My questions are: 1. Are they allowed to do this under the HIPAA law? If yes, what type of relationship will they have with the provider? 2. If a payer engages an agency to audit provider records does the payer become the BA of the provider? Regards, Vikas --- 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
PRIVACY: BA Agreements
Title: PRIVACY: BA Agreements I have drafted a BA Addendum and a BA Agreement. We will use the addendum with anyone we have a contract with. However, there are certain entities that do fee-for-service for us and do not have contracts (printing companies, lawyers, temp agencies, etc.) For these entities we will use the BA Agreement. I'm trying to make the language vague enough to work for all BA's so that as little tweaking has to be done for individual entities. But I'm having trouble with this, since we have to list the permitted and required uses and disclosures. The Addendum is easier because the original contracts say what they are using the info for. Is anyone willing share how they are handling this? Or does anyone have a BA Agreement (not addendum) at I could see to get an idea of how they are doing this? 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
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
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: Custodial parent rights to minor's PHI
Title: RE: Custodial parent rights to minor's PHI
I seem to remember from the August revisions, that this depends on the state laws. Someone correct me if I'm wrong.
Deborah
-Original Message-
From: Giesecke, Steve [mailto:[EMAIL PROTECTED]]
Sent: Friday, February 28, 2003 3:14 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Custodial parent rights to minor's PHI
I have a question regarding PHI disclosure with respect to minors when there has been a divorce and one parent has been assigned custody. My understanding is that only the parent with legal custody can (legally) access the children's PHI but I can't put my finger on the reference for this practice. Payers, for example, may have no way of knowing who has custody, let alone the marital status of a parent calling in concerning the PHI of a child. If I am reading this correctly, they will need to develop a system which allows their claims rep's and call centers to know who the custodial parent is. Does HIPAA defer to state law or is there a common law precedent or something specific I have missed in the Privacy Rule which addresses this situation?
Thanks for any information,
Steve Giesecke
Sierra Systems
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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.
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RE: Need for Business Associate Agreements
It would depend if they "used or disclosed PHI" on your behalf. If they do, you need a BAA. Hope that helps. 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: Beth Miller [mailto:[EMAIL PROTECTED]Sent: Friday, February 21, 2003 2:00 PMTo: WEDI SNIP Privacy Workgroup ListCc: Linda LeyvaSubject: Re: Need for Business Associate Agreements Hello, everyone - This is a variation on the question about the need for BAA's.My agencyanticipates beginning a new federal contract soon. As part of our original proposal, we obtained letters ofintent from various partners who would be working with us on the contract if we were awarded. Now that we've been awarded,we're intending to develop Memorandums of Understanding with these agencies, but are now wondering if we need BAA's with them as well as or instead of MOU's. My understanding, at this point, is that it would have to do with whether or not PHI is exchanged, handled, etc., between agencies and, if so, how. What does everyone else think? Beth Miller Grant Writer Tri-City Mental Health Center ---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: Disclosures of PHI to fully funded groups
We're still deciding. But right now, we're leaning towards only releasing PHI (other than enrollment and premium info) upon authorization whether they amend or not. All of the exceptions that would come about with some groups amending, some not, just leaves us open to many mistakes. 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: Waterhouse, Melissa [mailto:[EMAIL PROTECTED]]Sent: Thursday, January 23, 2003 3:03 PMTo: WEDI SNIP Privacy Workgroup ListSubject: Disclosures of PHI to fully funded groups I have a question regarding releasing PHI to fully funded groups. Are health plans considering releasing PHI to fully funded groups provided they have a signed certification on file or are plans only releasing summary/de-identified PHI to the fully funded groups and not using the certifications at all? We have checked state law and have not discovered any more stringent laws. I would like to hear how other plans are handling this situation. Melissa Waterhouse HIPAA Compliance Coordinator SummaCare Health Plan ---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: 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: When to have the patient sign an authorization
Jill, I'm not sure how a provider could have them sign an authorization when they arrive unless they already knew they would need one for a specific event. The regs say the authorization must be for a specific event or time period. I'm not sure you can get away with a blanket authorization. Deborah 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, January 20, 2003 1:20 PMTo: WEDI SNIP Privacy Workgroup ListSubject: When to have the patient sign an authorizationHow are providers in particular handling the singing of authorizations? Are practices having patients sign it when they first come in, for future disclosures, or as the specific situations arise (i.e., they later decide their atty. should see the medical records and sign an applicable authorization).Thanks as always for your input.Jill Rubin, Esq.(617)388-2404[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: 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: Appropriate physical safeguards
Title: RE: Appropriate physical safeguards --- 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 --- Christy, I would think, that since the bin is for allergy shots, you are telling them that this person not only is a patient, but what their condition is. -Original Message- From: SCHEEL, CHRISTY [mailto:[EMAIL PROTECTED]] Sent: Thursday, October 17, 2002 1:43 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: Appropriate physical safeguards --- 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 --- I would think the names would be okay as an incidental disclosure. You are not revealing anything other that what would be revealed as directory information. It would be the same as a name on a door or like you said, on the sign-in list. Christy Scheel, RHIA Corporate Compliance Specialist/Auditor Warm Springs Rehabilitation System Phone: (210) 832-2349 Fax: (210) 829-8741 Pager: (210) 203-4008 [EMAIL PROTECTED] -Original Message- From: Pat Bale [mailto:[EMAIL PROTECTED]] Sent: Thursday, October 17, 2002 12:33 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: Appropriate physical safeguards --- 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: the issue of incidental disclosure, my pediatric office has a nurse who gives allergy shots several hours a day. She keeps them in a plastic bin with each child's name on the drawer holding his serum. To involve and distract the child, she allows them to find their drawer, she checks to be sure it is correct, and then administers the shot. Technically, the child may see other children's names when he is searching for his. But isn't that an incidental disclosure similar to hearing a name in the waiting room or seeing a name on a sign in sheet? I really don't want to discontinue this practice, as the children really enjoy it and it makes getting a shot palatable. Any thoughts? Pat Bale, MHA 466 West Third Street Lexington, KY 40508 tel. fax: 859.254.0183 email: [EMAIL PROTECTED] -Original Message- From: Sparma, Deborah, nashccon [mailto:[EMAIL PROTECTED]] Sent: Thursday, October 17, 2002 1:05 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: Appropriate physical safeguards --- 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 --- From the OCR websits FAQ page: ·Can physician offices use patient sign-in sheets or call out the names of patients in their waiting rooms? Response: Yes, covered entities such as physician offices may use patient sign-in sheets or call out patient names in waiting rooms, so long as the information disclosed is appropriately limited. The Privacy Rule explicitly permits certain incidental disclosures that occur as a by-product of an otherwise permitted disclosure - for example, the disclosure to other patients in a waiting room of the identity of the person whose name is called. However, these incidental disclosures are permitted only to the extent that the covered entity has applied reasonable and appropriate safeguards (45 C.F.R. § 164.530(c)), and implemented the minimum necessary standard, where appropriate (45 C.F.R. §§ 164.502(b) and 164.514(d)). For example, the sign-in sheet may not display medical information that is not necessary for the purpose of signing in (e.g., the medical problem). For more information, see the preamble to the final modifications to the Privacy Rule (67 Fed. Reg. 53182, 53193-95 (August 14, 2002)). ·A clinic customarily places patient charts in the plastic box outside an exam room. It does not want the record left unattended with the patient, and physicians want the record close by for fast review right
