is this practice O.K.?
The practice that I am going to describe is quite common in our community but I am not sure it is acceptable. I wanted the opinion of the experts on this list. Occassionally, we run into a problem with a patient who seems to be doctor hopping and getting multiple prescriptions for narcotics. In order for the patient's principle physician to keep a close watch on the patient's use of narcotics and to avoid abuse/misuse of narcotics, the physician makes a deal with the patient. The deal is ALL prescriptions for narcotics must be funneled through one doctor-the primary care physician. The patient usually agrees but then (and here is where I am not sure if we are infringing on privacy)we can send an Alert to all the area pharmacies to alert them that this deal occurred and if the patient shows up at one of the area pharmacies with a narcotic prescription from someone other than the primary care physician, the patient is told that they have an order that they can not fill the prescription unless it comes from the designated doctor. Is this practice acceptable? Do we need the patient's consent to notify all heighborhood pharmacies? Is verbal consent acceptable? Can the information be sent to the pharmacies without the patient's specific consent (that is, the patient consented to the arrangement that one doctor fills all narcotic prescriptions but the patient did not consent to the information being sent to all area pharmacies? ) Thank you Rich Fairley, M.D. --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
named Privacy officer on NPP, posting
I have two quick questions for the group: 1. When your Notice of Privacy Practices (NPP) says to contact the Privacy Officer for such and such, does the Privacy Officer need to be a NAMED individual or can you just list the title of the contact person (e.g., the Privacy Officer)? 2.Since the law calls for a posting of the NPP, can we display a stapled copy of our 6 page NPP in a locked bulletin board (which would then just show the first page of the NPP) and then have a sign next to this displayed NPP that tells the inquisitive patient where in our office they can get a complete copy of the NPP if they wish? I realize that this proposal probably goes against the intent of this provision of the law but would it be technically be sufficient to meet the requirements of this provision? Reasons behind such a proposal are 1. Space is a problem, 2. Hanging up a 6-8 page NPP looks trashy. 3. All patient's will be personally handed the NPP so what's the point of posting it anyway? 4. And we would be posting it, it's just that you could not read all the pages of the posted version! Thanks for all advice provided. Rich Fairley --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
acknowledgement of Notice of Privacy Practices (NPP)
On April 15, 2003, we are anticipating that we simply do not have the staff available to supply all patients that walk in our door with our NPP. It's hard to find someone to do a job like this for only 3-4 months! We plan to hire college students to accomplish this task when school let outs in May. Nevertheless, in order to be compliant with the April 15, 2003 deadline, is it acceptable to mail out our NPP to scheduled patients ahead of time? Is the fact that we are mailing them out (and let's say we can keep track of who got SENT one) sufficient in itself to meet the requirement of a Good faith effort to obtain acknowledgement of receipt of NPP? That is, is simply mailing out the NPP adequate? If such a plan is not adequate, what about if we included an acknowledgement form in the mailing and asked the patient to return the form (and we did NOT supply an envelop or stamp)? Would that be enough, even if no one returns it? Thanks. Rich Fairley MD Dubuque, IA --- 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
