Rachel,
164.501 The definition for Health care operations (2) states that it
includes ...accreditation, certification, licensing, or credentialing
activities...
Was the state Department of Inspections and Appeals conducting the survey
for licensing purposes?
Molly
Molly Shek, MS,
Rachel:
I believe your thinking is correct. I attended the Regional HIPAA
Conference sponsored by DHHS in Atlanta. A somewhat similar question was
posed at that meeting, DHHS opined that you would need to account for such a
disclosure. In fact Linda Sanches who presented the material on
As the countdown decreases the questions increase.
For current patients, which of these options is best/right:
receive NPP and sign acknowledgement at first service delivery after
4/14/03
receive NPP and acknowledgement to sign and return on or before
4/14/03
I am trying to figure
In
regs 164.520 it states"No later than the date of the first service delivery, including service
delivered electronically, to such
individual after the compliance date for
the covered health care
provider;So it is a combo of the
two of them. Receive NPP and sign acknowledgement no later
Here I thought we were doing well and on track for April 14th, but an
interesting read last evening...I suppose it can never be easy. Can some
offer some clarification?
We provide Health and Dental insurance benefits (percentage of for full and
part-time) to our employees. I had understood that
It depends on whether the health and dental benefits are insured or
self-funded, and on whether the plan receives anything more than summary
health information (and enrollment/disenrollment info) from an insurer.
164.520(a)(2) addresses it.
(i)(A): the plan has to distribute it if the
We received a legal opinion regarding Organized Health Care Arrangements
(OHCA's) that I want some feedback on:
We have doctors/psychiatrists/psychologists that are independent
contractors. They come on site, do physicals, assessments, etc We have
considered them to be a part of our workforce
Based on
an informal poll it appears most psych professionals do not create or maintain
the sorts of notes that are defined by HIPAA as psychotherapy notes.
The HIPAA
exception evidently arose out of requests for special protection by those few
professionals who do create such notes.
Not
Rachel,
Since Leah and Dean already responded to the first part of your question
I'll just address the last part. Yes, 'wrongful' disclosures must be
included in an accounting.
Cheri
-Original Message-
From: rachelmcass [mailto:[EMAIL PROTECTED]
Sent: Wednesday, April 02, 2003
Licensing activities are included in health care operations and health care
operations do not have to be tracked for accounting of disclosures. I am
just going by the regulations. I don't think that that is stretching it.
Thanks.
Molly Shek, MS, RHIA
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