RE: NPP revisions
Doug, In accordance with the Office of Civil Rights Guidance issue in December 2002, only covered health care provider that have a direct treatment relationship with individuals are required to make a good faith effort to obtain the individual's acknowledgment of receipt of the notice - 45CFR 164.520(c)(2)(ii). This is in their QA section on NPP. Chris Apple Dept of Human Resources State of Nevada -Original Message- From: Doug Turpin [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 30, 2003 5:59 AM To: WEDI SNIP Privacy Workgroup List Cc: WEDI SNIP Privacy Workgroup List Subject: RE: NPP revisions Can anyone verify that health plans do not require obtaining an acknowledgement for NPP? Only providers? Matthew Rosenblum To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED] mrosenblum cc: @att.netSubject: RE: NPP revisions 01/29/2003 07:28 PM Please respond to Matthew Rosenblum Traci, You will still need to maintain (and track) those signed-acknowledgements. In the Committee's plan, it seems that there will be many more acknowledgements to maintain. I hope that this helps. Your questions are always welcome. Matt Matthew Rosenblum Chief Operations Officer Privacy, Quality Management Regulatory Affairs http://www.CPIdirections.com CPI Directions, Inc. 10 West 15th Street, Suite 1922 New York, NY 10011 (212) 675-6367 [EMAIL PROTECTED] CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by E-Mail at the address shown and delete the original message. Thank you. AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener información privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si usted ha recibido esta comunicación por error, por favor no lo distribuya. Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message- From: Noel, Linda A. [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 3:15 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: NPP revisions Expense. Linda Noel Corporate Privacy Officer Corporate Compliance Orlando Regional Healthcare 321-843-8693 -Original Message- From: Traci Winter [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 2:27 PM To: WEDI SNIP Privacy Workgroup List Subject: NPP revisions 164.520 [c][2][iv] Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision and promptly comply with the requirements of paragraph [c][2][iii] of this section, if applicable. I just want to run this by everyone, in our HIPAA committee meeting today we have decided to provide a NPP and get a signed acknowledgement of receipt with each admission to home care services, even if the patient was previously receiving services from our agency. The reasoning
Re: NPP revisions
You're correct, Doug. Here's an excerpt from the recent guidance on the Privacy Regs: [begin quote] Q: Are health plans required to make a good faith effort to obtain from their enrollees a written acknowledgment of receipt of the notice? A: No. Under the HIPAA Privacy Rule, only covered health care providers that have a direct treatment relationship with individuals are required to make a good faith effort to obtain the individual's acknowledgment of receipt of the notice. See 45 CFR 164.520(c)(2)(ii). [end quote] Connie Hein Paramore Consulting e-Commerce for healthcare www.hipaasurvival.com - Original Message - From: Doug Turpin [EMAIL PROTECTED] To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED] Cc: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED] Sent: Thursday, January 30, 2003 7:58 AM Subject: RE: NPP revisions Can anyone verify that health plans do not require obtaining an acknowledgement for NPP? Only providers? Matthew Rosenblum To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED] mrosenblum cc: @att.netSubject: RE: NPP revisions 01/29/2003 07:28 PM Please respond to Matthew Rosenblum Traci, You will still need to maintain (and track) those signed-acknowledgements. In the Committee's plan, it seems that there will be many more acknowledgements to maintain. I hope that this helps. Your questions are always welcome. Matt Matthew Rosenblum Chief Operations Officer Privacy, Quality Management Regulatory Affairs http://www.CPIdirections.com CPI Directions, Inc. 10 West 15th Street, Suite 1922 New York, NY 10011 (212) 675-6367 [EMAIL PROTECTED] CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by E-Mail at the address shown and delete the original message. Thank you. AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener información privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si usted ha recibido esta comunicación por error, por favor no lo distribuya. Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message- From: Noel, Linda A. [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 3:15 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: NPP revisions Expense. Linda Noel Corporate Privacy Officer Corporate Compliance Orlando Regional Healthcare 321-843-8693 -Original Message- From: Traci Winter [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 2:27 PM To: WEDI SNIP Privacy Workgroup List Subject: NPP revisions 164.520 [c][2][iv] Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision and promptly comply with the requirements of paragraph [c][2][iii] of this section, if applicable. I just want to run this by everyone, in our HIPAA committee meeting today we have decided to provide a NPP and get a signed acknowledgement of receipt with each admission to home care services, even if the patient was previously receiving services from our agency. The reasoning is, with the rapid turnover of our patients it would be extremely difficult to track which edition of our NPP a patient had received, and since our patients sometimes are re-admitted to our services years down the road it would allow us to make sure we had documentation that the NPP had been given. We may put a section on our acknowledgement form for the patient to check/sign if they are refusing a copy due to previous receipt. I think this should cover us pretty well??. any cons to the plan? Traci Winter Hospitals Home Health Care, Inc. --- 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
NPP revisions
164.520 [c][2][iv] Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision and promptly comply with the requirements of paragraph [c][2][iii] of this section, if applicable. I just want to run this by everyone, in our HIPAA committee meeting today we have decided to provide a NPP and get a signed acknowledgement of receipt with each admission to home care services, even if the patient was previously receiving services from our agency. The reasoning is, with the rapid turnover of our patients it would be extremely difficult to track which "edition" of our NPP a patient had received, and since our patients sometimes are re-admitted to our services years down the road it would allow us to make sure we had documentation thatthe NPP had been given. We may put a section on our acknowledgement form for the patient to check/sign if they are refusing a copy due to previous receipt. I think this should cover us pretty well . any cons to the plan? Traci Winter Hospitals Home Health Care, Inc. --- 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: NPP revisions
My non-legal opinion is that this is overkill...and that patients will annoyed. I don't believe that was the intent of the privacy regulations. 1. Why do you expect your NPP to change frequently? Is it so specific that every new request for data (such as from a new accreditation agency) will cause it to be updated? 2. Could you date or letter your NPP so it is easier to recognize which edition/version was given? If your application can accomodate a yes/no to show they received it, why could it not accomodate a date or letter? 3. Think of the costs of this practice. Will you be keeping paper copies, which must be filed, or electronic copies, which take up disk space? My personal opinion only. Mimi Mimi Hart Ó¿Õ* Research Analyst, HIPAA Iowa Health System 319-369-7767 (phone) 319-369-8365 (fax) 319-490-0637 (pager) [EMAIL PROTECTED] Matthew Rosenblum [EMAIL PROTECTED] 01/29/03 18:56 PM Traci, You will still need to maintain (and track) those signed-acknowledgements. In the Committee's plan, it seems that there will be many more acknowledgements to maintain. I hope that this helps. Your questions are always welcome. Matt Matthew Rosenblum Chief Operations Officer Privacy, Quality Management Regulatory Affairs http://www.CPIdirections.com http://www.cpidirections.com/ CPI Directions, Inc. 10 West 15th Street, Suite 1922 New York, NY 10011 (212) 675-6367 [EMAIL PROTECTED] CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by E-Mail at the address shown and delete the original message. Thank you. AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener información privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si usted ha recibido esta comunicación por error, por favor no lo distribuya. Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message- From: Noel, Linda A. [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 3:15 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: NPP revisions Expense. Linda Noel Corporate Privacy Officer Corporate Compliance Orlando Regional Healthcare 321-843-8693 -Original Message- From: Traci Winter [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 2:27 PM To: WEDI SNIP Privacy Workgroup List Subject: NPP revisions 164.520 [c][2][iv] Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision and promptly comply with the requirements of paragraph [c][2][iii] of this section, if applicable. I just want to run this by everyone, in our HIPAA committee meeting today we have decided to provide a NPP and get a signed acknowledgement of receipt with each admission to home care services, even if the patient was previously receiving services from our agency. The reasoning is, with the rapid turnover of our patients it would be extremely difficult to track which edition of our NPP a patient had received, and since our patients sometimes are re-admitted to our services years down the road it would allow us to make sure we had documentation that the NPP had been given. We may put a section on our acknowledgement form for the patient to check/sign if they are refusing a copy due to previous receipt. I think this should cover us pretty well**. any cons to the plan? Traci Winter Hospitals Home Health Care, Inc. --- 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 This e-mail message and any attached files are confidential and are intended solely for the use of the addressee(s) named above. If you are not the intended
Re: NPP revisions
Yes, it is not necessary. You only have to obtain written acknowledgment of an individual's receipt of your NPP one time (on the first service delivery after the compliance date). After that, if you subsequently revise your NPP you only need to post the revised notice in your facility, and make it available to people on request. There is no need to track which version of the NPP they received, nor is there a requirement to obtain another acknowledgment if you issue a later revision of your NPP. I believe this has been clarified on the CMS web site thorugh their FAQ's, and in the December guidance issued by OCR. I'm sure I could cite you the exact source if you have trouble convincing your other committee members. Noel Chang -- Open WebMail Project (http://openwebmail.org) -- Original Message --- From: Traci Winter [EMAIL PROTECTED] To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED] Sent: Wed, 29 Jan 2003 14:26:30 -0500 Subject: NPP revisions 164.520 [c][2][iv] Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision and promptly comply with the requirements of paragraph [c][2][iii] of this section, if applicable. I just want to run this by everyone, in our HIPAA committee meeting today we have decided to provide a NPP and get a signed acknowledgement of receipt with each admission to home care services, even if the patient was previously receiving services from our agency. The reasoning is, with the rapid turnover of our patients it would be extremely difficult to track which edition of our NPP a patient had received, and since our patients sometimes are re- admitted to our services years down the road it would allow us to make sure we had documentation that the NPP had been given. We may put a section on our acknowledgement form for the patient to check/sign if they are refusing a copy due to previous receipt. I think this should cover us pretty well... any cons to the plan? Traci Winter Hospitals Home Health Care, Inc. --- 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 --- 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. 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
